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:
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To structure investments and projects in countries which are Mauritius double tax avoidance treaty partners.
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Holding rights to intellectual property, such as industrial designs, copyrights, trademarks, patents
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Trading, Consultancy services, Collective Investment Schemes, Closed-Ended Funds, Protected Cell Companies
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Regional Headquartering; financing; Marketing centre
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Investment Funds (Closed-Ended, Open-ended (mutual Funds), Variable Capital Companies (VCC), Protected Cell Companies Funds (‘PCC’);
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Operate in various financial/insurance and other fintech licensed activities offered by the Financial Services Commission (FSC’)
Key Features
Corporate Taxation: 15%, but depending on certain revenue streams and certain substance conditions being observed, the company may claim partial exemption where the effective tax rate of the company could be reduced to 3% (kindly refer to list of income/activities available for the partial exemption)
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: Yes
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
Non-Financial Activities
Investment Holding (excluding IP Rights)
Tax Treatment
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80% exemption regime applicable to:
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Foreign-source dividends (subject to conditions and limitations on deductible amounts).
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Foreign-source interest income.
Minimum Annual Expenditure
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USD 12,000 per year.
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Where Global Business Companies (GBCs) hold IP rights, they must demonstrate expenditure incurred in Mauritius that is proportionate to the Research and Development activities related to the relevant IP rights.
Employment Requirement
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No minimum employment requirement in Mauritius.
International Trading
Tax Rate
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Income tax rate: 3%
Minimum Annual Expenditure
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USD 15,000 per year.
Employment Requirement in Mauritius
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Annual turnover below USD 100 million: Minimum 1 employee (direct or indirect).
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Annual turnover above USD 100 million: Minimum 2 employees (direct or indirect).
Consulting and Services Activities
Tax Rate
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Income tax rate: 15%
Minimum Annual Expenditure
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USD 15,000 per year.
Employment Requirement in Mauritius
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Annual turnover below USD 100 million: Minimum 1 employee (direct or indirect).
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Annual turnover above USD 100 million: Minimum 2 employees (direct or indirect).