MAURITIUS GLOBAL BUSINESS COMPANY (GBC)

GBC companies are incorporated under the Mauritius Companies Act 2001, as amended and licensed by the FSC. They are resident in Mauritius for tax purposes and are eligible to the extensive DTAA (Double Taxation Avoidance Treaty) network, provided they hold a TRC (Tax Residence Certificate) issued by the MRA (Mauritius Revenue Authority). GBC replaces the previous GBC1 regime.

Substance Requirements

In order to issue a GBC Licence, the Mauritius FSC considers whether the company has substance in Mauritius through its management and control. The following substance requirements are considered:
  • Shall have or has at least 2 directors, resident in Mauritius;
  • Shall maintain or maintains at all times its principal bank account in Mauritius;
  • Shall keep and maintain or keeps and maintains, at all times, its accounting records at its registered office in Mauritius;
  • Prepare or proposes to prepare its statutory financial statements and causes or proposes to have such financial statements to be audited in Mauritius;
  • Provides for all meetings of directors to include at least 2 directors from Mauritius.

The Company must meet, at all times, the following additional pre-defined substance requirements:
  • carry out its core income generating activities in, or from, Mauritius by:
    • employing either directly or indirectly a reasonable number of suitably qualified persons to carry out the core activities; and
    • having a minimum level of expenditure, which is proportionate to its level of activities
  • be managed and controlled from Mauritius; and
  • be administered by a Management Company

Indicative minimum annual expenditure in Mauritius

Category Sub-Category Minimum Annual Expenditure (USD)
Non-Financial Investment Holding (excluding IP rights) 12,000
Non-Investment Holding 15,000

Taxation

Effective as from January 2019, the current deemed Foreign Tax Credit regime available to GBC1 companies will be abolished.

There will be an introduction of an 80% exemption regime on the following income, subject to meeting the above pre-defined substance requirements

  • Foreign dividend, subject to amount not allowed as deducton in source country
  • Foreign source interest income
  • Profit attributable to a permanent establishment of a resident company in a foreign company
  • Foreign source income derived by a c Collective Investment Scheme (CIS), Closed End Funds, CIS manager, CIS administrator, investment adviser, or asset manager licensed or approved by the FSC
  • Income derived by companies engaged in ship and aircraft leasing

The following transitional period is available to existing GBC1 companies:

       

Transitional Period for existing GBC1 companies

  GBC1 Licence issue date   Grandfathering
  On or before 16 October 2017   Grandfathered up to 30 June 2021
  After 16 October 2017   Grandfathered up to 31 December 2018


Double Taxation Agreements

Mauritius has so far concluded Double Taxation Agreements with the following 44 countries:

AFRICA EUROPE ASIA OTHERS
Botswana Belgium India Australia
Cabo Verde Croatia Malaysia Barbados
Congo Cyprus Nepal Kuwait
Egypt France Oman Qatar
Lesotho Guernsey Pakistan U.A.E.
Madagascar Germany Bangladesh
Mozambique Italy China
Namibia Luxembourg Singapore
Rwanda Malta Sri Lanka
Senegal Monaco Thailand
Seychelles Sweden
South Africa U.K.
Swaziland
Tunisia
Uganda
Zambia
Zimbabwe
(7 awaiting ratification, 4 awaiting signature, 21 in negotiation)
       

GENERAL

  Type of the company   GBC
  Common law or civil law   Common Law
  Readymade company available   Yes
  Non-English company allowed   Yes
  Legislations   Mauritius Companies Act 2001 and the Financial Services Act 2007

DIRECTORS

  Minimum number of resident Directors   2
  Corporate directors permissible   No
  Publicly accessible records of directors   No
  Location of directors meetings   In Mauritius for tax treaty access

SHAREHOLDERS (MEMBERS)

  Minimum number of shareholders   1
  Corporate shareholders permissible   Yes
  Local shareholder requirement   No
  Location of shareholders meetings   Allowed to be held by proxy
  Publicly accessible records of shareholders   No

BENEFICIAL OWNERS

  Publicly accessible records of beneficial owners   No
  Shares may be held by a nominee on behalf of beneficial owner client   Yes

COMPANY SECRETARY

  Appointment of qualified resident Company Secretary   Yes

SHARE CAPITAL

  Standard currency   USD, GBP or EURO
  Permitted currencies   any (except Mauritian Rupees)
  Registered shares   Bearer shares not permitted

ACCOUNTS AND RETURNS

  Requirement to file annual Accounts   Yes, within 6 months of financial year end
  Audit requirement   Yes
  Publicly accessible Accounts   No
  Requirement to file annual company return   No
  Requirement to file income tax return   Yes

OTHER

  Migration/redomiciliation of companies to or from Mauritius   Yes
  Double taxation treaty access   Mauritius has an extensive double taxation avoidance treaty network with 44 countries
  Requirement   registered office and licensed Secretary / Registered Agent in Mauritius
  Trading restrictions   if duly licensed by the Mauritian authorities, a GBC may carry on the business of banking, insurance, reinsurance, fund administration, etc
  Powers A GBC has the same powers as a natural person, including the right to sue and be sued. It is a separate legal entity with limited liability and has perpetual existence
  Name restrictions: it is prohibited (or requires requisite licence) for a GBC name to contain words such as "Bank", "Trust", "Building Society", "Insurance", or which suggest the patronage of any Government. It is prohibited to use a name already in use.
  Language of GBC name: while normally in English or French, a GBC name can be in any language, but must be accompanied by an approved translation in English.

The above information is for guidance only and therefore the material contained herein should not be regarded, viewed or considered as an advice. You should contact your tax or professional adviser/s for appropriate detailed professional advice. We accept no liability for the accuracy of the information contained herein, nor any loss arising from reliance on it.

If you require a Global Business Company, please call our Expert Team who can assist you with your requirements. You are invited to call us at (230) 245 6703. You may send your enquiries by email: contact@premier.mu or by fax at (230) 245 6704.

 
           
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