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Mauritius

Global Business Company (Private company limited by shares)

Mauritius is a politically stable jurisdiction and the largest international financial and business hub in the Indian Ocean region with a strong liberal economy, a reputable banking system and a wide offer of qualified professional services.

Its pro-business and flexible regulatory framework provides reliability and security for the incorporation of international companies.

Under the Companies Act, 2001 and the Financial Service Act 2007, companies may apply for a Global Business License (GBL) that allows them to carry out Business outside the jurisdiction and benefit from an advantageous tax regime.

Companies holding the Global Business License Category I (GBC1, also known as GBL1) are entitled to do business internationally, may only undertake activities set out in the Business Plan filed with the Financial Services Commission (FSC) at the time of application for a license or as amended and notified to the FSC, and may conduct business with residents subject to the approval of the FSC.

GBC1 companies may conduct financial services activities such as banking, insurance, assurance, reinsurance, fund management, collective investment schemes, trust management, trusteeship business provision, if the relevant license is obtained.

GBC1 companies may apply for a tax residence certificate and benefit from an advantageous tax regime and a broad network of double taxation treaties.

Mauritius GBC1 companies are subject to corporate tax at a 15% rate, but there is available a unilateral foreign tax credit of up to 80%. Therefore, the effective tax rate of a GBC1 is a net of just 3%. Capital gains are not subject to taxation and there is no withholding tax on dividends, royalties and interests paid to non-residents.

In addition, dividends paid by a foreign entity of which the GBC1 owns a minimum of 5% of share capital will qualify for the underlying foreign tax credit, and therefore taxes paid on such income out of dividends may receive a credit.

To qualify for a tax residence certificate GBC2 Companies must fulfill the following requirements:

  • The company shall at all times have at least two Directors resident in Mauritius;
  • All meetings of the Board of Directors shall be chaired and minuted in Mauritius (Teleconferences accepted);
  • The company has a registered address in Mauritius;
  • The statutory documents, company papers and accounting records are kept at the registered office in Mauritius;
  • The company shall ensure that all its banking transactions are directed through a bank account in Mauritius;
  • The company has a local Company Secretary and local auditors; The TRC is renewable on an annual basis and pursuant to a specific DTA with specific formalities and undertakings to be complied with.

The tax residence certificate is renewable on an annual basis.

In addition, GBC1 companies may benefit from more than 30 tax treaties to avoid double taxation, being excellent vehicles for investments into China, India, Indonesia, Thailand, Singapore, South Africa, and many more.

They may be incorporated with as little as $1 of paid up capital, and shares may be issued with or without par value and fractional. Confidentiality is ensured as details of shareholders, directors, beneficial owners, as well as company accounts are not available to the public.

To qualify for a Global Business License Category II, a company must meet at least one of the following criteria:

  • the corporation has or shall have office premises in Mauritius; or
  • the corporation employs or shall employ on a full time basis at administrative/technical level, at least one person who shall be resident in Mauritius; or
  • the corporation's constitution contains a clause whereby all disputes arising out of the constitution shall be resolved by way of arbitration in Mauritius;
  • the corporation holds or is expected to hold within the next 12 months, assets (excluding cash held in bank account or shares/interests in another corporation holding a Global Business License) which are worth at least USD 100,000 in Mauritius;
  • the corporation's shares are listed on a securities exchange licensed by the Commission; or
  • it has or is expected to have a yearly expenditure in Mauritius which can be reasonably expected from any similar corporation which is controlled and managed from Mauritius.

In Mauritius, companies may be structured as protected cell companies.

Protected cellular companies are entities made up of a core and a several ring-fenced protected cells, creating separate portfolios of assets and liabilities which are statutorily segregated.

Although the cells of a protected cellular company do not have a separate legal personality, assets and liabilities of each cell must be kept separated and separately identifiable from the assets and liabilities of the protected cell company (core) and of each of the others cell.

Cellular companies have both core capital and cellular capital, which is the capital invested in individual cells.

Creditors of a cell are unable to seek recourse from the assets of any of other cells or of the core. This corporate vehicle provides protection contagion to fund promoters as an umbrella unit trust.

In addition, this corporate structure provides several cost savings such as avoiding to setting up new entities, lower costs on corporate governance, company administration and compliance.

Mauritius is a non-Black-listed jurisdiction, as it has agreed to implement the OECD’s automatic exchange of information for tax purposes (AEoI) by 2018 and is not considered as a non-cooperative country and territory by the Financial Action Task Force. Mauritius has also concluded Tax information exchange agreements (TIEa) with 8 jurisdictions.

All in all, GBC1s are excellent vehicles for investment, investment holding and fund management purposes, as well as to hold intellectual property rights, international trade and financial services, among others. They benefit from an advantageous tax regime with an effective tax rate that may be as little as 3%, access to a broad list of tax treaties and no withholding taxes on dividends and royalties, as well as exemption on capital gains and tax credits on dividends received.

Taxes

Corporate income tax – GBC1 companies are liable to income tax at the rate of 15%.

However, under the Tax sparing credits regime, the effective rate of taxation in Mauritius can be reduced from 15% to 3%. If GBC1 companies elect not to provide written evidence to the Commissioner of Income Tax showing the amount of foreign tax charged, they may enjoy a deemed taxation at 80% of the normal tax rate of 15%, reducing the effective rate of tax in Mauritius from 15% to 3%.

If the GBC1 owns at least 5% of an underlying company, credit will be available on foreign tax paid on the income out of which the dividend was paid.

A non-resident Mauritius company, which pays a dividend and has also received a ‘secondary dividend’ from another non-resident Mauritius company (where it owns a minimum of 5% of its share capital), will qualify for the underlying foreign tax credit and this secondary dividend will be allowed as a foreign tax credit.

Capital gains are tax-exempt and there is no withholding tax on payment of dividends, interests or royalties paid to non-residents.

Mauritius does not have any thin capitalisation rules, so interest and royalty payments may be fully deducted from taxes due in Mauritius.

Personal income tax – The main tax on resident individuals is income tax at a 15% rate. To be a tax resident an individual must spend more than 6 months in the country in a year.

However, expat employees resident in Mauritius of a GBC1 pay are subject to a reduced personal income tax of 7.5%. In addition, each GBC-1 company is allowed 2 expatriated employees to import cars and household goods duty-free.

Other taxes - In Mauritius there is no capital gains tax, real property tax, inheritance tax or estate duty, capital transfer tax, gifts tax or wealth tax. There is VAT at 15% levied on the supply of goods and provision of services.

  • Offshore Income Tax Exemption
  • Offshore capital gains tax exemption
  • Offshore dividends tax exemption
  • CFC Rules
  • Thin Capitalisation Rules
  • Patent Box
  • Tax Incentives & Credits
  • Property Tax
  • Wealth tax
  • Estate inheritance tax
  • Transfer tax
  • Capital duties
  • 15% Offshore Income Tax Rate
  • 15% Corporate Tax Rate
  • 0% Capital Gains Tax Rate
  • 0% Dividends Received
  • 0% Dividends Withholding Tax Rate
  • 0% Interests Withholding Tax Rate
  • 0% Royalties Withholding Tax Rate
  • 0 Losses carryback (years)
  • 0 Losses carryforward (years)
  • FIFO Inventory methods permitted
  • 4% Social Security Employee
  • 10% Social Security Employer
  • 15% Personal Income Tax Rate
  • 15% VAT Rate
  • 56 Tax Treaties

Country details

Mauritius
MUR
Port Louis
Africa
e n - M U , b h o , f r
1294104

The Republic of Mauritius is a sovereign island country located in the southwest of the Indian Ocean, about 900 kilometers from Toamasina, a town on the easternmost coast of Madagascar and approximately 3800 kilometers southwest of Cape Comorin on the southern tip from India.

In addition to the island of Mauritius, the republic includes the islands St. Brandon, Rodrigues and the Agalega Islands. Mauritius forms part of the Mascarene Islands, along with the French island of Reunion, about 170 kilometers to the southwest.

Mauritius is inhabited by about 1.4 million people. Its capital and most populated locality is Port Louis.

The people of Mauritius are multiethnic, multi-religious, multicultural and multilingual. The Mauritian Creole, French, English and Bhojpuri are its vernacular languages, plus other 9 languages spoken in the territory.

Its official currency is the Mauritian rupee (MUR).

Mauritius is highly ranked for democracy and for economic and political freedom.

The Head of State of Mauritius is the President, who is elected for a period of five years by the National Assembly, the Mauritian unicameral parliament.

The National Assembly has 62 members elected by direct and popular suffrage and comprises between 4 and 8 members elected by minorities representing ethnic minorities, depending on the election results. The government is headed by the prime minister and a council of ministers.

Since its independence from the British in 1968, Mauritius has seen a dazzling evolution.

The island went from being a low-income country with per capita income, in which the economy was based on agriculture, to be a country with the status of an emerging and constantly developing country with intermediate incomes and a diversified economy based on a growing industrial, financial and tourism sector.

During this period of economic growth, the country grew at a rate of 5 to 6% per year. This result translates into a significant improvement in the quality of life and a significant increase in life expectancy, a decline in infant mortality and a great infrastructural development.

Regarding the primary sector, sugar cane accounts for 90% of crops and accounts for 25% of exports. Livestock in Mauritius mainly comprises porcine and caprine, and fishing is also an important source of income.

Its main industrial sectors are the textile, information and communications technology and seafood processing, as well as petrochemical and chemical industry in Port Louis.

Tourism is its more prominent sector and a significant source of its foreign exchange revenues. Mauritius is a growing tourism destination for its natural beauty and man-made attractions, multi-ethnic and cultural diversity of the population, tropical climate, beautiful beaches and water sports.

The issuance of stamps for collection is also a source of income.

The financial sector is a major economic pillar on Mauritius economy, with more than 10,000 offshore companies incorporated and a broad offer banking, insurance and reinsurance services, captive insurance managers, trading companies, ship owners or managers, fund managers and international corporation services.

Tax treaties

Country Type Date Signed
Singapore DTC  1995-08-19
Swaziland DTC  1994-06-29
Kuwait DTC  1997-03-24
Malta DTC  2014-10-15
China DTC  1994-08-01
Mozambique DTC  1997-02-14
Gabon DTC  2013-07-18
Senegal DTC  2002-04-17
Thailand DTC  1997-10-01
Australia TIEA 2015-03-10
Malawi DTC  2012-08-18
Croatia DTC  2002-09-06
Seychelles DTC  2012-08-18
Oman DTC  1998-03-30
Barbados DTC  2004-09-28
Zambia DTC  2012-08-18
Qatar DTC  2008-07-28
Kenya DTC  2012-05-07
Congo, Republic of the DTC  2010-12-20
Germany DTC  2011-10-07
India DTC  1982-08-24
Nigeria DTC  2012-08-10
Monaco DTC  2013-04-13
Luxembourg DTC  1995-02-15
Lesotho DTC  2012-08-18
Tunisia DTC  2008-02-12
Malaysia DTC  1992-08-23
Denmark TIEA 2011-12-01
Belgium DTC  1995-07-04
United Kingdom DTC  1981-02-11
Faroe Islands TIEA 2011-12-01
United Arab Emirates DTC  2006-09-18
Botswana DTC  1995-09-26
Uganda DTC  2003-09-19
Tanzania DTC  2012-08-18
Madagascar DTC  1994-08-30
Bangladesh DTC  2009-12-21
Finland TIEA 2011-12-01
Rwanda DTC  2001-07-30
Guernsey DTC  2013-02-06
United States TIEA 2013-12-27
Congo, Democratic Republic of the DTC  2012-08-18
Norway TIEA 2011-12-01
Italy DTC  1990-03-09
Namibia DTC  1995-03-04
France DTC  1980-12-11
Russian Federation DTC  1995-08-24
Cyprus DTC  2000-01-21
Greenland TIEA 2011-12-01
Pakistan DTC  1994-09-03
Sri Lanka DTC  1996-03-12
Iceland TIEA 2011-12-01
Zimbabwe DTC  1992-03-06
South Africa DTC  1996-07-05
Sweden DTC  2011-12-01
Nepal DTC  1999-08-03

Tax treaties Map

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Services

We can help you incorporate a Global Business Company (Private company limited by shares) in Mauritius for $12,000.


Description


Mauritius Private Company with Global Business License – US$12,000.00 (All included)



  • Bound set of Constitutional Documents

  • Certified Copies of Constitutional Documents for bank account opening

  • Government Fees

  • Assistance writing Business Plan

  • GBC 1 Business Licence and provision of legal certificate

  • Organisational minutes

  • Processing fees (Financial Services Commission)

  • Processing Fees & Company Registration Fees (Registrar of Companies)

  • Annual Licence (Financial Services Commission)

  • Tax Residence Certificate

  • 2 Corporate Directors

  • Registered Office & Registered Agent fee

  • Courier fees


Time to form: 3 to 4 weeks.


All our incorporation services include a yearly consulting session, a dedicated account manager and access to our global network of trusted business services, including introductions to accountants, financial, tax and legal advisors at no cost.


Annual Fees – US$10,500.00


Including:



  • Global Business Licence fee payable to the FSC

  • Registration fee payable to the Registrar of Companies

  • Tax Residence Certificate (“TRC”) fee payable to the MRA

  • Provision of two resident directors, which is a mandatory requirement

  • Provision of secretarial services including all board meetings / shareholders meetings requirements (organizing meeting, preparing board papers, conducting meeting with directors, taking of minutes of proceedings)

  • Provision of registered office address

  • Acting as Registrar and Transfer Agent (includes maintenance of all relevant registers, ie, directors register, register of members, secretary’s register)

  • Acting as the main contact point for all relevant parties (authorities, shareholders, banker, lawyer, auditors etc)

  • Performance of all banking transactions upon receipt of relevant instructions. (Our officers can act as cosignatory to the bank account)

  • Submission of all applications as may be required from time to time by the directors

  • Ensuring compliance with all relevant legislations

  • Preparation of yearly financial statements in accordance with IFRS and any such other frequency where management accounts would be required

  • Liaison with accountants and auditors with respect to financial statements and audit

  • Preparation and filing of quarterly and yearly tax returns, and tax payments with the Mauritius Revenue Authority

  • Renewal of the Tax Residence Certificate on a yearly basis

  • Ongoing due diligence in line with the AML/CFT laws of Mauritius


Bank Account Options



  • Mauritius Bank Account (Remotely) – US$500.00

  • Labuan (Malaysia) Bank Account (Remotely) – US$500.00

  • Offshore Bank Account* (Remotely) – US$300.00

  • Curaçao Bank Account (Remotely) – US$500.00

  • Bahamas Bank Account (Remotely) – US$500.00

  • Singapore Bank Account (In-person) – US$900.00

  • Hong Kong Bank Account (In-person) – US$1,200.00

  • Switzerland Bank Account (In-person) – US$1,200.00

  • Crypto-Friendly Bank Account (Remotely) – US$3000.00


We include introductions to payment processors or merchant accounts with all of our incorporation services. Whether you just need standard credit card processing or specialized services for high risk processing, we are happy to help you with introductions that can empower your business.


*Offshore Bank Accounts: Belize, Puerto Rico, Nevis, Antigua, Saint Lucia.  Other bank account options may be available depending on business profile and turnover.





Click here to incorporate your Mauritius GBC.

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Disclaimer

Although we use our best efforts to keep the information of this site accurate and up-to-date, we make no representations or warranties with respect to the accuracy, applicability, fitness, or completeness of the contents of this website. We disclaim any warranties expressed or implied, merchantability, or fitness for any particular purpose. We shall in no event be held liable for any loss or other damages, including but not limited to special, incidental, consequential, or other damages. The contents of this website are just for illustrative purposes and are NOT to be considered as a legal opinion or tax advice and should not be relied upon as such. Far Horizon Capital Inc., and any associated company, is not engaged in the practice of law or tax. If you wish to receive a legal opinion or tax advice on the matter(s) in this website please contact our offices and we will refer you to an appropriate legal practitioner. Use of our websites FlagTheory.com, Incorporations.io, Residencies.io, Passports.io, is subject to our terms and conditions.

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