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The corporate vehicles available to carry global business activities from within Mauritius are companies holding a companies holding Category 1 Global Business Licence (GBC1) , companies holding a Category 2 Global Business Licence(GBC2).

Category 1 Global Business Licence [GBC 1]
As defined under the Financial Services Act 2007, a GBC1 is a company engaged in global business and which is carried with persons all of whom are resident outside Mauritius and where business is conducted in a currency other than the Mauritian rupee.

The GBC1 can be formed as a Private or Public Company, Companies limited by shares, limited or unlimited life company. Its main feature is that it is entitled to relief and fiscal advantage through the double taxation treaties that Mauritius has signed with various countries.

Features Category 1 Global Business Licence Company (GBC1)

• One shareholder allowed.


• Corporate shareholder allowed.


• Corporate body cannot be appointed as director


• No minimum capital requirement


• Shares can be with/without par value


• Only registered shares are allowed


• Redeemable preference shares may be issued


• Access to the extensive and expanding double tax treaty network


• For tax residency purposes, needs two local resident directors


• Need to appoint a local secretary


• Has to file annual audited accounts to the Financial Services Commission


• Audited accounts must be filed 6 months after year end and in accordance with International Financial Reporting Standards


• Dividend payable to non-resident are tax exempt


• The Cat 1 Global Business Company is subject to a tax of 15% in Mauritius. However, after applying the deemed amount of foreign tax credit of 80%, the tax rate is reduced to 3%.

Category 1 Global Business Licence Company [GBC 1]
Tax Relief

A GBL1 will get Double Taxation Relief given the following conditions are met:

• Effective management is exercised in Mauritius


• There are two resident directors


• A bank account is operated in Mauritius


• The Registered office and all statutory records are kept in Mauritius


• The meetings of the Board of Directors are held in Mauritius.At least 1 director resident in Mauritius.

Category 2 Global Busines Licence Company [GBC 2]
A GBC2 provides greater flexibility and is a suitable vehicle for holding and managing private assets. The GBC2 may either be limited by shares or by guarantee or simply unlimited. A GBC2 may also be structured as a limited life company.

Features of Global Business Category 2 Global Business Licence Company (GBC2)

• No minimum capital requirement


• No need to file audited annual returns


• Must have a Registered Agent and a Registered Office in Mauritius


• Can appoint a foreign secretary and director


• Exemption from all taxation and duties in Mauritius


• Shareholders/Directors can be individuals or corporate body


• May issue only Registered shares


• Shares may be redeemed or bought back


• Meeting can be held outside Mauritius or via Telephone or other electronic means


• A copy of all documents must be kept at the Registered Office


• Directors may appoint any other officer/agent to assist them in their tasks


• Can hold shares in a GBL1

Category 2 Global Busines Licence [GBC 2]
Prohibitions imposed on Category 2 Global Business Licence Company (GBC2)

• Nominate resident as shareholders


• Raise capital from the public


• Take advantage from double taxation treaties signed by Mauritius


• Carry on any banking, insurance, reinsurance business and financial services and collective investment schemes


• Operate in the Freeport


• Deal with resident of Mauritius


• Carry any dealings in Mauritian rupees


• Hold/own any interest in immovable property in Mauritius


• Hold any shares debentures/interest in any domestic company or other entities


• Issue of bearer shares

Trusts set up under the Trust Act 2001 provide an effective and legitimate means of sheltering ones' assets. Various types of Trusts may be set up by residents and non residents in Mauritius such as charitable, discretionary, purpose and trading trusts. A trust may carry on a Qualified Global Business after obtaining a Category 1 Global Business Licence. However, a trust may not apply for a Category 2 Global Business Licence

Taxation of Trusts
A trust is liable to income tax at the rate of 15% if the settlor and beneficiaries are non-residents or hold a Category 1 Business licence or is a purpose trust. However, such trust will be entitled to the presumed foreign tax credit of the higher rate suffered or 80% of its chargeable income, or may deposit a declaration of non-residence within 3 months after the expiry of the income year. It will then be exempt from income tax.

The main features of Mauritian Trusts are:

• Confidentiality of trustee’ deliberations, identity of Settlor and Beneficiaries.


• Possibility to appoint a protector and to establish letters and memorandum of wishes.


• Anti forced heirship rules.


• Migration of Trust possible.


• Concept of managing and custodian trustee (up to four trustees).


• A resident trust may benefit from the network of Double Tax Treaties.


• Charitable Trusts are exempt from tax.


• The proper law of the trust is the one chosen by the Settlor, or the one implied in the Trust Deed. If no law is chosen, the one which is most closely connected at the time of creation of the Trust will be treated as the proper law.

Corporate and Legal Structure
Global Funds registered with the Financial Services Commission in Mauritius are commonly structured as companies incorporated under the Companies Act 2001 and licensed as a company holding a Category 1 Global Business Licence. Such a structure, referred to as an Investment Company, is defined as one where the company’s business consists of investing its funds mainly in securities with the aim of spreading investment risk and giving members of the company the benefit of the results of the management of its funds.


An Investment Company can take the form of:

• A close-ended company which has a fixed share capital. Investors do not have the right to call for their shares to be redeemed at net asset value by the company. A close-ended company can be listed on the Stock Exchange enabling investors to buy and sell shares in the market thereby preventing any lock in. The company may be formed with a limited life after which the assets are distributed to investors on winding up.


• An open-ended company which has a variable share capital. Investors are allowed to redeem their shares at net asset value at pre-determined times in accordance with the articles of association.