Current Node

The tax environment

Individuals

All Mauritians living on the island are taxable by the government. A foreigner who spends more than 183 days* of the tax year can be tax resident in Mauritius.

As the country has signed a non-double taxation agreement with 46 countries, the status of Mauritian tax resident leads to a certain number of advantages such as:

  • Tax treaty benefits with treaty countries
  • No inheritance tax
  • Dividends from local companies and capital gains are tax exempt
  • Income tax for individuals and companies harmonised at 15%
  • Entitlement to tax exemption thresholds

For enterprises

  • No tax on capital gains generated by the enterprise
  • Local dividend is tax exempt
  • 80% tax exemption on interest income or and foreign dividends
  • No withholding tax on the repatriation of money generated by your activities by way of dividend, or royalties paid out of foreign source income or interest paid by company holding a Global Business Licence (GBL)
  • A Corporate Social Responsibility (CSR) system is imposed on all companies by which the Mauritius Revenue Authority (MRA) takes a levy of 2% on profits generated by the company except on specific entities such as companies operating as a GBL company

*Conditions apply

Current Node

Doing business in Mauritius

Several further conditions must be fulfilled in order to obtain the right to start up an economic activity on Mauritian territory.

As per the Companies Act of 2001, every domestic company must have at least one director who is ordinarily resident in Mauritius as well as a registered office address on the island (not a PO Box).

A foreigner who wants to open a business in Mauritius needs to first set about incorporating a domestic company.

You want to take your business global and move to Mauritius, learn more here >

The reputation of Mauritius as an International Financial Centre rests on the quality of its services and its pool of highly qualified professionals. The Financial Services Act (FSA) adopted in 2007, simplifies the regulatory regime and consolidates the legislative framework of the global business sector.

In monitoring the conduct of business activities of its licensees, the Financial Services Commission (FSC) focuses inter alia on market conduct, Anti-Money Laundering and Combating the Financing of Terrorism requirements, corporate governance principles and international norms and standards

There are two different types of companies in Mauritius namely domestic and Global Business Companies.
Domestic Company - trading mainly onshore and may be involved mainly in exporting activities as well
Global Business Licence – where the majority of shares or voting rights or the legal interest in a resident company, are held by a person who is not a citizen of Mauritius and such company proposes to conduct business principally outside Mauritius

 

Current Node

Global Business Licence (GBL) - previously Category 1 Global Business Licence

A resident corporation which proposes to conduct business principally outside Mauritius shall apply to the Financial Services Commission (FSC) for a Global Business Licence (previously Category 1 Global Business Licence). A resident corporation is a body corporate formed or registered in Mauritius, and may include any trust, société, partnership or any body of persons governed by the laws of Mauritius.

The FSC assesses whether the ultimate purpose of the applicant is an investment or a service to be made or provided outside Mauritius. The GBC is required to abide by the following:

  • Carry out its core income generating activities in or from Mauritius by:
    • employing directly or indirectly a reasonable number of qualified persons to carry out the core activities;
    • having a minimum level of expenditure proportionate to its level of activities.
  • Be administered by a management company; and
  • Be managed and controlled from Mauritius.

Forms of GBC 1

A GBC 1 can be in the form of a Trust, Société and Partnership.

Trusts

Trusts are set up under the Trusts Act 2001 as charitable, discretionary or purpose trusts.

Société

Société en Nom Collectif (partnership) and "Société en Commandite Simple" set up under the Code de Commerce Amendment Act 1985 (limited partnership) may be used to structure investments in the global business sector.

Protected Cell Company

A GBL can also be structured in the form of a Protected Cell Company (PCC). The PCC is a legal structure made up of cellular and non-cellular assets. It provides legal segregation of assets attributable to each cell of the company whether owned by individuals or body corporate. The PCC offers a wide range of applications as set out under Protected Cell Companies (Amendment of Schedule) Regulations 2005.

 

Current Node

Applying for a FS-4.1 Global Business Licence

An applicant for a Global Business Licence must submit the following forms/documents to the FSC, through a Management Company.

 

A GBL is tax resident in Mauritius and may apply for a Tax Residence Certificate from the Director General of the Mauritius Revenue Authority should this be required by the tax authorities in the jurisdiction in which the company is conducting its business. Click here for more information.

Investors may benefit from an extensive network of Double Taxation Agreements (DTAs). Entities holding a Global Business Licence wishing to avail to the benefits of a tax treaty must obtain a Tax Residence Certificate issued by the Mauritius Revenue Authority. Further information is available on the website of the Mauritius Revenue Authority.

Management Companies may apply for Global Business Licences via the Online Submissions Platform, a secure web-based application which allows Management Companies to also submit online payments through Electronic Payment Instructions via commercial banks.  The Guide to Online Submissions Platform sets the protocol for online submissions.

 

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