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Global Business Companies

A GBC is a company engaged in qualified global business and which is carried on from within Mauritius with persons all of whom are resident outside Mauritius.

Confidentiality is strictly observed in terms of the Financial Services Act of Mauritius. No person or body is authorized to disclose information or present documentation to any court, tribunal, committee of inquiry or other authority in Mauritius unless ordered to do so by a Court of Law on application by the Director of Public Prosecution for inquiry into the trafficking of narcotics and dangerous drugs, arms trafficking or money laundering as defined under existing legislation. Upon application to the FSC, full disclosure is required on the beneficial owners of the company. However, such information is not available for public inspection.

As per the Companies Act and the Financial Services Act of Mauritius, a GBC is mainly used for Financial Services business (subject to additional licenses) and for investment holding activities especially when income from overseas is mainly in the form of dividends, interest, and capital gains. It is eligible for benefits from the network of Double Taxation Agreements (DTA) thus making it an effective corporate vehicle for international tax planning.
Other activities authorised by a GBC are:

Capital

  • There is no minimum stated capital.
  • Capital can be denominated in any currency except Mauritian Rupee.
  • GBC companies are subject to no restrictions as to the distribution of their assets. They may purchase their own shares subject to the Solvency Test. The share may either be cancelled or held as treasury shares.

Shares & Shareholders

  • Registered shares, preference shares, redeemable shares and shares with or without voting rights.
  • Par value shares if any may be stated in more than one currency.
  • Minimum of 1 shareholder and same rule applies if the company is a wholly owned subsidiary.
  • Shareholders may be individual or corporate entity.
  • Shares may be subscribed by nominees but beneficial owners should be disclosed.
  • Annual meeting must be held every year not later than 15 months after previous

    meeting, and not later than 6 months after balance sheet date. Meetings need not be held in Mauritius.

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Tax Residency

A Global Business Company wishing to benefit from the tax relief under the Double Taxation Agreements, requires a Tax Residence Certificate (TRC), which is issued by the Commissioner of Income Tax in Mauritius. To be tax resident, the company must demonstrate that the ‘effective management and control’ is in Mauritius. To satisfy this test the applicant company is required to:

New tax regime

GBCs are liable to taxes at the rate of 15% but tax relief is available within the network of DTAs.

A partial exemption regime is now in place whereby an income tax exemption of 80% on the following categories of income is applicable, provided that the enhanced substance requirements are met.

Profit attributable to a permanent establishment which a resident company has in a foreign country.
Foreign source dividend provided that it has not been allowed as a deduction in the country of source
Income derived by a collective investment scheme (CIS), closed end fund, CIS manager, CIS administrator, investment adviser or asset manager, as the case may be. They should be licensed or approved by the Financial Services Commission established under the Financial Services Act.

Income derived by companies engaged in ship and aircraft leasing. GBL companies may still claim credit for actual foreign tax incurred

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Global Business Companies

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