Global Business Companies (GBCs) Mauritius

About Global Business Companies (GBCs)

Companies incorporated in Mauritius for the purpose of doing business primarily outside Mauritius are designated as Global Business Companies (GBCs) and are governed by the Financial Services Act 2007.

Mauritius GBCs are specifically designed for resident entities engaging in qualifying global business activities, which must be conducted primarily with non-residents of Mauritius and in foreign currencies.

Under the Financial Services Act 2007, GBCs are permitted to engage in various business activities, including but not limited to:

01

Investment Holding.

02

Collective Investment Schemes.

03

Leasing Activities.

04

Investment Advisory services.

05

International Trading.

06

Consultancy services.

07

Other Financial Services activities.

A GBC is not permitted to engage in business activities in Mauritius, except in respect of incidental activities that are necessary for the company’s operations.

GBCs are particularly beneficial for businesses requiring a strategic location, a robust regulatory framework and access to Mauritius’ extensive network of Double Taxation Agreements (DTAs), offering tax efficiency for operations spanning multiple jurisdictions.

They are also the most efficient structures through which to apply for specialised Non-Banking Financial Services licences to take advantage of the preferential GBC tax regime in Mauritius under which 80% of ‘gross revenue’ is exempted from taxation, which reduces the effective income tax rate to 3%.

Global Business Companies (GBCs)

In 2016, Mauritius joined the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was initiated to address the specific tax challenges arising from the digitalisation of the global economy by ensuring that profits can be taxed in the place where economic activity and value creation take place.

Joining the OECD/G20 Inclusive Framework commits signatories to implementing the international standards introduced by the OECD. As a result, in 2019 Mauritius abolished the 80% Deemed Foreign Tax Credit (DFTC) regime, which was previously available to companies holding a Category 1 Global Business Licence, and the rate of tax for both domestic companies and GBCs was harmonised at 15%.

In its place, a new licence – the Global Business Licence (GBL) – was introduced for foreign-controlled companies wishing to conduct business principally outside Mauritius, together with an 80% partial tax exemption regime on the following income:

Foreign dividend derived by a company.
Interest derived by a company other than bank, non-bank deposit taking institution, money changer, foreign exchange dealer, insurance company, leasing company, and company providing factoring, hire purchase facilities or credit sales facilities.
Interest derived by a person from money lent through a Peer-to-Peer Lending platform
Profit attributable to Foreign Permanent Establishment (PE).
Income, other than interest, derived by Collective Investment Scheme (CIS) or a Closed End Fund
Income derived by CIS manager, CIS administrator, investment adviser, investment dealer or asset manager licensed by the Financial Services Commission (FSC).
Income derived by a company engaged in the leasing of ships / aircraft / locomotives and trains, including rail leasing.
Reinsurance/reinsurance brokering activities.
Leasing and provision of international fibre capacity.
Sale, financing, arrangement, asset management of aircraft and its spare parts and related aviation advisory services.
Income derived by a company holder of a Payment Intermediary Services (PIS) licence issued by the FSC.
Income derived by a company holding a Robotic & Artificial Intelligence Enabled Advisory Services licence issued by the FSC.

Companies licensed under the GBL are generally known as Global Business Companies (GBCs).

The 80% exemption is available to GBCs that satisfy the substance requirements issued by the Financial Services Commission (FSC) to qualify as tax resident in Mauritius. To qualify, a GBC must:

Carry out its Core Income Generating Activities (CIGA) in or from Mauritius.
Employ directly or indirectly, an adequate number of suitably qualified persons to conduct its CIGA.
Incur a minimum expenditure proportionate to its level of activities.

It is also mandatory for a GBC to be ‘managed and controlled’ from Mauritius and administered by a licensed management company, such as Sovereign Mauritius, that holds a Management Company licence from the FSC.

Setting up a Global Business Company (GBC)

Setting up a GBC in Mauritius requires a minimum of one shareholder, who can be non-resident in Mauritius, and two local directors who are resident in Mauritius and must exercise independence and actively participate in decision-making to ensure the company is managed and controlled from Mauritius.

Sovereign Mauritius can be appointed to fulfil the requirement for two resident directors for a Mauritius GBC. We can also provide the physical registered address in Mauritius and the necessary company secretarial services.

Additionally, GBCs must:

Maintain their principal bank account in Mauritius.
Hold board meetings in Mauritius.
Keep accounting records at its registered office in Mauritius.
Prepare statutory financial statements that are audited in Mauritius.
Meet with the minimum substance requirements in Mauritius.

An applicant for a Global Business Licence is required to submit the appropriate application to the FSC, channeled through a company, such as Sovereign Mauritius, that holds a Management Company (MC) licence from the FSC.

Before an applicant is accepted, the MC must carry out such vetting procedures on beneficial owners, promoters, controllers, directors and shareholders of an applicant company, which includes:

Verified copy of passport.
Verified proof of residential address.
Verified CVs.
Bank Reference Letters, which are usually required at the time of bank account opening.

Other supporting documentation may be requested, depending on structures and cases, including a detailed business plan, current financial statements and financial projections in respect of the business personal financial statements for shareholders.

A Tax Residence Certificate (TRC) is of great importance to Mauritius Global Business Companies because it enables them to claim relief from withholding taxes under Mauritius’s extensive network of double taxation treaties as a tax resident entity.

The Mauritius Revenue Authority (MRA) will only process applications that have been recommended by the Financial Services Commission (FSC). Applicants are therefore requested to ensure recommendation from FSC is received before engaging with the MRA.