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.
Prior to 2018, any resident corporation that proposed to conduct business outside Mauritius could apply to the Financial Services Commission (FSC) for a Category 1 Global Business Licence (GBC1) or a Category 2 Global Business Licence (GBC2).
A GBC1 is a company that is resident in Mauritius for tax purposes. It is therefore liable to tax at a flat rate of 15% on chargeable income, but there is a Deemed Foreign Tax Credit (DFTC) of 80%, resulting in a maximum effective tax rate of 3%. Upon obtaining a Tax Residence Certificate (TRC) from the Mauritius Revenue Authority, a GBC1 also has access to Mauritius’ network of double tax treaties.
A GBC1 is permitted to undertake any business activity that is not illegal or against public policy, including those involving capital raising from the public. A GBC1 may be a locally incorporated company or a branch of a foreign company and may be structured as a protected cell company, as an investment company, a fund or a limited partnership.
A GBC2 is not considered resident in Mauritius for tax purposes and therefore is not liable to tax in Mauritius. As a result it is unable to qualify for double taxation treaty relief. A GBC2 is suited for trading, holding and managing private assets and may not engage in certain authorised activities such as financial services.