Global Business Company (GBC)

Mauritius Global Business Licence (GBC)

A Global Business Company (GBC) is a company engaged in qualified business activities, which is carried out from within Mauritius and with persons all of whom are resident outside of Mauritius, and where business is conducted in a currency other than the Mauritian rupee. However, a GBC can deal with Mauritian residents with the special approval of the Financial Services Commission (FSC) in Mauritius.

GBC offers a range of benefits for global business ventures such as:

Ease of Doing Business

Mauritius is renowned for its pro-business environment and ease of doing business. Setting up a GBC is a seamless and straightforward process, with no minimum capital requirement and minimal red tape. The business-friendly legal framework, political stability, and skilled workforce make Mauritius a prime location for global companies looking to establish a presence in Africa, Asia, or other international markets.

Global Access

A GBC in Mauritius offers unparalleled access to global markets. With a wide network of double taxation treaties (DTAs) with over 45 countries, including India, China, UK, France, and South Africa, a GBC can help you minimize international tax liabilities and optimize your business operations. Mauritius is also a member of the Common Market for Eastern and Southern Africa (COMESA) and the Southern African Development Community (SADC), providing further opportunities for trade and investment in the region.

Tax Advantages

One of the key advantages of a GBC is its favorable tax regime. With a maximum. corporate tax rate of 15% or as low as 0-3% for some few activities, your business can enjoy significant tax savings compared to traditional jurisdictions. Additionally, GBCs are exempt from capital gains tax, withholding tax, and dividends tax, making Mauritius an attractive destination for international tax planning.

A Word of Caution

While a GBC offers numerous advantages, one of the main challenges is increased scrutiny and regulations from global authorities due to concerns about offshore tax planning and money laundering. It’s crucial to ensure that your business operates in compliance with the relevant laws and regulations to avoid any legal or reputational risks.

Substance and other requirement for GBCs

A GBC is considered as resident company for tax purposes in Mauritius only if:

it has economic ‘substance’ in Mauritius and is not a mere ‘P.O Box company’
it derives its Core Income Generating Activities (CIGA) from Mauritius and
it is ‘centrally managed and controlled’ from Mauritius

A GBC must satisfy the following criteria:

Has a minimum of 2 directors, resident in Mauritius at all times, who are appropriately qualified and are of sufficient calibre to exercise independence of mind and judgement. (We provide nominee services)
Is administered by a Management Company to act as a qualified company secretary
Maintains its main bank account in Mauritius at all times
Maintains and keeps, at all times, its accounting records at its registered office in Mauritius
Annual Tax return must be filed with the Mauritius Revenue Authority
Prepares its statutory financial statements and provide financial statements to be audited in Mauritius

Board meetings are chaired from Mauritius (teleconference mode accepted)
Has a minimum annual expenditure e.g., USD 12,000 p.a. for investment holding activity, or USD15,000 or more for non-investment holding activity to satisfy the economic ‘substance’ requirement. (The minimum annual expenditure includes annual licence fees, audit fees, accounting fees, management fees, any travelling costs, accommodation, office rental, etc.)
Has a minimum direct or indirect employment in Mauritius. However, there is no minimum direct or indirect employment requirement for a GBC carrying out ‘Investment Holding’ activities.
For other activities, the minimum employment (1 or 2) normally, depending on the nature of the activity of the GBC.

If the above criterias are not met, the GBC will be considered as non-resident for tax purposes in Mauritius and will not be taxed in Mauritius. It will instead be taxed in the country from where it is centrally managed and controlled.

The following global business activities can be carried out by a GBC:

Aircraft Financing and Leasing
Assets Management
Consultancy Services
Employment Services
Information and Communication Technologies
Insurance
Licensing and Franchising

Logistics and or Marketing
Operational Headquarters
Pension Funds
Shipping and Shipping Management
Trading
Financial Services
Any other activity as may be approved by the Commission

Taxation

The rate of tax for GBC’s are harmonised at 15%. However, some GBCs can benefit from a partial exemption of 80% of the income streams as listed below, and thus be effectively taxed at only 3%, assuming that the substance requirement is satisfied:

Investment Holding (passive) i.e., foreign dividends
Foreign Interest income and royalties
Profit gained to a permanent establishment of a resident company abroad
Interest resulting from money lent through peer-to-peer lending platform
Income derived by a Collective Investment Scheme (CIS)
Income generated by a corporation operating in aircraft leasing and ship
Income derived by a company from reinsurance and reinsurance brokering
Income resulting by a company from leasing and provision of international fibre
Income derived by a company from the sale of aircraft spare parts and linked advisory services

Tax Holidays in Mauritius

Tax Holiday of 5 years for Asset Manager Certificate, Treasury Management, Global Legal Advisory Services, Investment Banking, etc.)

Tax Holiday of 8 years for Global or Regional Headquarters Administration Licence. Must provide service to three related entities. Establishing a Global or Regional Headquarter in Mauritius can provide significant advantages in terms of tax, cost and operational efficiency.

Mauritius Global Business Licence (GBC)

GBC offers a range of benefits for global business ventures such as:

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