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Mauritian Products

Global Business Corporation (GBC)

The GBC is allowed to be incorporated in Mauritius or be registered as a branch of a foreign company. It is tax resident and have substance in Mauritius.

Common uses of a GBC:

  • To structure investments and projects in countries which are Mauritius double tax avoidance treaty partners.
  • Holding rights to intellectual property, such as industrial designs, copyrights, trademarks, patents
  • Trading, Consultancy services, Collective Investment Schemes, Closed-Ended Funds, Protected Cell Companies
  • Regional Headquartering; financing; Marketing centre

 

KEY FEATURES

Corporate Taxation: 15%

Type of Law: Hybrid
Double taxation treaty access: Yes, with over 40 countries

  • Stated Capital
    Currencies: Major currencies except Mauritian Rupees
    Minimum paid up: No minimum requirements
    No par value shares: Allowed
  • Directors
    Corporate directorship: Not allowed
    Local directors: Minimum 2 required for access to tax treaties
  • Shareholders
    Corporate shareholder: Allowed
  • Company Secretary
    Required: Yes, local and qualified
  • Registered office in Mauritius
    Yes
  • Company Records
    A GBC is required to keep its records (original minutes, resolutions, register of directors/ members, constitution, accounting records) at its registered office in Mauritius
  • Financial Statement 
    Requirements to prepare: Yes
    Audit requirements: Yes
    Filing of audited financial statement: Within 6 months after the balance sheet date
  • Tax Return
    Requirements for preparation: Yes
    Filing of Tax Return: Within 6 months after the balance sheet date

 

 

 

SUBSTANCE REQUIREMENTS

Category

Sub-Category

Tax Rate

Minimum annual expenditure (USD)

Minimum Employment in Mauritius (Direct or Indirect)

Non-Financial

Investment Holding (excluding IP rights*)

 

An exemption regime of 80% on:

i.         Foreign dividend, subject to the amount not allowed as deduction in source country

 

ii.           Foreign sourced interest income

 

12,000

 

*GBC holding IP rights will be required to demonstrate that they have incurred expenditure in Mauritius which is proportionate to the Research and Development of the relevant IP rights

No minimum employment

Non-Financial

Non-Investment Holding:

International Trading

Income tax rate: 3%

15,000

If annual turnover is:

< than USD 100M: Minimum 1

>USD 100M: Minimum 2

Non-Financial

Non-Investment Holding:

Consulting/ Services activity

Income tax rate: 15%

15,000

If annual turnover is:

< than USD 100M: Minimum 1

>USD 100M: Minimum 2

Financial

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Authorised Company (AC)

An AC is treated as a non-resident entity in Mauritius for tax purposes provided that its central management and control is outside of Mauritius.

An AC is a flexible business entity which is commonly used for:

  • Investment holding
  • Trading
  • Consultancy activities
  • One-off projects.

 

KEY FEATURES

Corporate Taxation: No corporate tax if central management and control outside Mauritius
Double taxation treaty access: No

  • Directors
    Minimum director: One
    Corporate director: Allowed
  • Shareholders
    Minimum shareholder: One
    Corporate shareholder: Allowed
  • Company Secretary
    Required: May or may not have a Company Secretary 
  • Registered Agent
    Required: Yes
  • Registered office
    In Mauritius: Yes
  • Holding of shares
    May hold shares in other companies
  • Financial Statement 
    Requirements to prepare Financial Summary: Yes
    Audit requirements: No
    Filing of Financial Summary: Within 6 months after the balance sheet date
    Requirements to prepare and file Annual Tax Return with the Mauritius Revenue Authority, (“MRA”): Yes

Protected Cell Companies (PCC)

A PCC provides flexibility and security for international investment structuring. It is a single legal entity that can divide its assets between different cells within the company. When sub-divided, the assets of each cell are deemed to be entirely separate from each other and the creditors of a cell only
have recourse against that particular cell.

A PCC may carry out either of the following qualified global business activities:

  • Asset holding
  • Collective investment schemes
  • Insurance business
  • Specialised collective investment schemes
  • Structured finance business

 

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Limited Partnership (LP)

A Limited Partnership (LP) combines features of both a company and of a partnership. It gives owners the flexibility of operating as a partnership while having a separate legal identity like a private limited company.

Common uses of an LP:

  • Collective investments schemes and closed-end funds
  • Private equity and venture capital schemes
  • Joint venture
  • Holding property interests
  • Tax and financial planning
  • Estate planning
  • Asset protection

KEY FEATURES

Legal Personality: Can be registered with or without legal personality.
The general partners may elect that a LP shall have a legal personality at any time during the lifetime of the LP.

Duration: Subject to the terms of the partnership agreement, the LP also have a continuous and successive existence, through present and future partners until dissolution

  • Registered office
    Yes, in Mauritius which must be at the office of a licensed Management Company.
  • Registered Agent
    Unless at least one general partner is resident in Mauritius, every LP shall at all times have and maintain in Mauritius a registered agent.
  • Company Secretary
    An LP holding a Global Business Licence (GBL) must appoint a Company Secretary, resident in Mauritius
  • Tax Treaty access
    Yes, with over 40 countries
  • Partnership Agreement
    Every LP shall have a partnership agreement which shall be binding upon the partners, their assignees and subsequent partners.
  • Company Records
    A LP holding a GBL is required to keep its records at its registered office.
    Should the LP decide to keep its records elsewhere, the Registrar of Limited Partnerships/ Registrar of Companies will need to be informed.
  • Accounts
    Every LP shall prepare financial statements in accordance with and comply with the International Accounting Standards, within 6 months after the balance sheet date of the LP.
    An LP holding a GBL shall file its financial statements and report of the auditor with the FSC
  • Annual Return
    Every LP shall once a year submit to the Registrar an annual return of the LP.
  • Tax Return
    LP holding a GBL are required to submit Advance Payment System (APS) statements and pay tax on a quarterly basis either on the basis of either their previous year’s income or the income of the current quarter

Investment Dealer

A person shall hold an Investment Dealer Licence or being licensed as a representative of an Investment Dealer by the Financial Services Commission (“FSC”) to:

  • Act or hold himself out as an intermediary in the execution of securities transaction on behalf of other persons;
  • Trade or hold himself out to trade in securities as principal for his own account with the intension of selling them to the public; or
  • Underwrite or distribute or hold himself out to underwrite or distribute securities on behalf of an issuer or a holder of securities

 

No person other than a body corporate may apply for an Investment dealer Licence.

 

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Investment Adviser

A person shall hold an Investment adviser licence   or   being licensed as a representative of an investment adviser by the Financial Services Commission (“FSC”) to:

  • Advise guide, or recommend other persons, or hold himself out to advise, guide or recommend other persons, whether personally or through printed materials or by other means, to enter into securities transactions;
  • Manage or hold himself out to manage, under a mandate, whether discretionary or not, a portfolio of securities.

No person shall give advice on Corporate finance advisory matters concerning securities transactions.

 

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Domestic Company

A Domestic Company is registered with the Registrar of Companies and governed under the Companies Act 2001. The activities can be conducted with residents of Mauritius as well as with non-residents of Mauritius.

 

A domestic company can be set up for various activities:

  • Trading
  • Investment Holding,
  • Consulting Services. amongst others.

KEY FEATURES

Corporate Taxation: 15%

Corporate Social Responsibility (CSR): 2%
Double taxation treaty access: Yes, with over 40 countries

  • Stated Capital
    Currency: Mauritian Rupees
    Minimum paid up: No minimum requirements
  • Directors
    Resident Director: At least 1 director resident in Mauritius
    Corporate Director: Not allowed
  • Shareholders
    Corporate and Individual shareholder: Allowed
  • Company Secretary
    Required: Yes
  • Registered office in Mauritius
    Yes
  • Financial Statements 
    Required: Yes
  • Corporate Social Responsibility (CSR)
    Required: Yes, 2% of chargeable income of the preceding year
  • Data Protection
    Registration: Required to have a data controller

Special Licences in Mauritius

  • Global Headquarters Administration
    Global headquarters administration is defined as the provision of at least 3 of the following services to at least 3 ‘related’ corporations:

    1. Administration and general management;

    2. Business planning and development and coordination;

    3. Economic or investment research and analysis;

    4. Services related to international corporate headquarters in Mauritius; and

    5. Such other global headquarters administration services as may be specified in Financial Services Commission (FSC) Rules.
  • Global Treasury Activities
    Global treasury activities relate to the provision of at least 3 of the following services to at least 3 ‘related’ corporations:

    1. Arrangement for credit facilities, including credit facilities with funds obtained from financial institutions in Mauritius or from surpluses of network companies;

    2. Arrangement for derivatives;

    3. Corporate finance advisory;

    4. Credit administration and control;

    5. Factoring, forfeiting and re-invoicing activities;

    6. Guarantees, performance bonds, standby letters of credit and services relating to remittances;

    7. Management of funds for designated investments; and

    8. Such other global treasury activity as may be specified in FSC Rules.
  • Global Legal Advisory Services
    An entity which main activity is to provide legal services pertaining to global business, international arbitration, corporate law, taxation law and foreign and international law can apply to the FSC for a Global Legal Advisory Services Licence.
  • Overseas Family Office (Single) Licence and Overseas (Multiple) Licence
    The Overseas Family Offices constitute new lines of financial offerings targeting at investment advice, such as budgeting, insurance, charitable trusts, family-owned businesses, wealth transfer, and tax services.

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Trusts

Mauritius Trusts are governed by The Trusts Act 2001 (the “Act”). A trust is a flexible vehicle which can be structured to assist a parent or individual in alignment of their objectives or/and ambitions.

 

Uses of Trusts

A Trust has a wide variety of uses and benefits, which may include:

  • Asset protecting and ring-fencing
  • Estate planning / transmission
  • Asset holding/ Immovable Property1
  • Structured finance

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Private Trust Company

A Private Trust Company (PTC) is a company formed to act as Trustee to a number of trusts, either for the benefit of a single family, or for distinct (but related) family groups.

 

The PTC takes on the trusteeship of the various family trusts and act as the registered owner of their assets.

 

A PTC provides:

  • an elegant solution for a family situation where a greater degree of control over the Trust assets is required
  • flexibility in investment decision making process and allows members of succeeding generations to sit on the Board and take part in running the family business.

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Mauritius Foundation

Foundation in Mauritius are governed by the Mauritius Foundations Act 2012 (the ‘Foundations Act’) and managed by the Foundation Council which carries out the objectives and purposes of a Foundation.

 

A Foundation is a legal entity without shareholder and member but with beneficiaries. A Foundation has some common features with a Trust and a Corporate entity. It can have varied objectives; charitable, estate planning or commercial.

 

A Foundation is generally established to reflect the wishes of a Founder(s), who may be an individual or a legal entity. The management of its investments and assets are handled by its Council

 

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