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Company Services

Global Business Company (GBC) in Mauritius

The principal international corporate vehicle in Mauritius — offering access to an extensive treaty network, a competitive tax regime and a credible, well-regulated jurisdiction.

The Global Business Company (GBC) is the primary vehicle used for international structuring through Mauritius. Regulated by the Financial Services Commission (FSC) under the Financial Services Act 2007, a GBC is tax resident in Mauritius and is entitled to access the country's extensive network of double taxation agreements — one of the broadest in Africa and among the most useful for investment into Africa and Asia. The GBC operates under a partial exemption regime which, when applicable, allows 80% of certain categories of income to be exempt from Mauritius corporate tax, resulting in an effective tax rate as low as 3% on qualifying income. To benefit from this regime and from treaty access, a GBC must demonstrate genuine economic substance in Mauritius — a requirement that has been significantly tightened since 2019 in line with international BEPS standards. The GBC is used by fund managers, private equity structures, holding companies, royalty vehicles and trading entities that require a credible, treaty-efficient offshore hub.

Key features and uses of a GBC

Treaty Network Access

Mauritius has an extensive network of double taxation agreements, including treaties with India, China, several African nations and European countries. A GBC that is genuinely tax resident in Mauritius can invoke these treaties to reduce withholding taxes on dividends, interest, royalties and capital gains from treaty-partner jurisdictions — subject to treaty-specific conditions and anti-avoidance provisions.

Partial Exemption Regime

Under the Mauritius Income Tax Act, a GBC can claim an 80% partial exemption on qualifying income streams, including foreign dividends, foreign-source interest, income from collective investment schemes, income from qualified peer-to-peer lending and gains on disposal of securities. The effective corporate tax rate on such income is 3% of the gross income. Detailed conditions apply and professional tax advice is essential.

Investment Holding and Fund Platforms

Many private equity funds, family office holding structures and collective investment schemes are structured through or above a GBC. The combination of treaty access, low effective rates and a common law legal system makes Mauritius an attractive holding layer for African and Asian investments.

Regional Headquarters and Service Companies

Multinational groups use GBCs as regional headquarters, treasury centres, intellectual property holding vehicles or intra-group service companies, particularly for Africa-facing operations. The Mauritius legal system, English-language environment and time zone (UTC+4) facilitate efficient management.

Incorporation and licensing process

01

Structural assessment

We review your investment or business objectives, intended activities, shareholder and beneficial owner profile, and the relevant treaty network to confirm a GBC is the appropriate structure and to design the substance plan.

02

KYC and due diligence

All shareholders, directors, beneficial owners and controlling parties must provide certified identification, proof of address and source-of-funds documentation. Enhanced due diligence may apply for politically exposed persons or complex ownership chains.

03

FSC licence application

We prepare and submit the GBC licence application to the Financial Services Commission, together with the constitution, business plan, group structure chart, KYC dossiers and any supporting materials. The FSC typically issues an approval in principle within three to six weeks for straightforward applications.

04

Incorporation and bank account

On FSC approval, the company is incorporated with the Registrar of Companies. Corporate documents are issued and we assist with the opening of a Mauritius bank account and the implementation of the substance programme.

Key requirements

  • Licensed Management Company must be appointed as registered agent
  • Registered office must be maintained in Mauritius
  • At least two resident directors (individuals resident in Mauritius) required
  • Genuine economic substance in Mauritius — see our Economic Substance page for full details
  • Annual audited financial statements required
  • Annual corporate tax return filing with the Mauritius Revenue Authority
  • FATCA and CRS reporting obligations where applicable
  • KYC and beneficial ownership disclosure to the FSC and Registrar of Companies

Indicative costs

The following ranges are indicative only and do not constitute a quotation. GBC running costs depend significantly on the level of substance required, the number of directors, the complexity of the structure and the scope of services engaged. Contact us for a tailored proposal.
البند النطاق الاستدلالي
GBC incorporation and licence application (one-off) USD 3,000 – 6,000
Annual FSC licence fee (government fee) USD 335 (as at current schedule)
Annual registered office and secretarial services USD 2,000 – 4,000
Resident director service (per director per annum) USD 2,500 – 5,000
Annual audit and tax compliance USD 2,500 – 6,000

الأسئلة الشائعة

Does a GBC automatically benefit from Mauritius's double taxation treaties?
Not automatically. To access treaty benefits, a GBC must be genuinely tax resident in Mauritius, which requires it to be managed and controlled from Mauritius. The company must meet the economic substance requirements and, in some cases, obtain a Tax Residency Certificate from the Mauritius Revenue Authority. The specific conditions of each bilateral treaty also apply.
What substance requirements does a GBC need to meet?
A GBC must have its central management and control exercised in Mauritius. This typically requires resident directors who actively participate in board decisions, board meetings held in Mauritius, strategic decisions made locally, and adequate operational infrastructure. The level of substance required scales with the nature and volume of the company's activities. We cover this in detail on our Economic Substance page.
Can a GBC hold shares in companies outside Mauritius?
Yes. One of the most common uses of a GBC is as a holding company for subsidiaries or investee companies in Africa, Asia and elsewhere. Dividends received from foreign subsidiaries may qualify for the 80% partial exemption, subject to conditions.
How long does it take to set up a GBC?
From submission of a complete application with full KYC documentation, the FSC typically takes three to six weeks to approve a straightforward GBC application. Incorporation with the Registrar of Companies follows shortly thereafter. Bank account opening is a separate process and timelines vary by institution.
Is a GBC suitable for fund management activities?
A GBC can be used as a fund vehicle or as a fund manager, but regulated fund management activities require an additional FSC licence (e.g. a CIS Manager licence or Investment Adviser licence). Our team can advise on the appropriate licensing category for your specific fund strategy.
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