Key Takeaways
- A GBC operates under a defined Mauritius legal framework that sets out its features, ownership rules, and reporting duties.
- Management and director substance requirements must be met for a GBC to maintain its standing and intended tax treatment.
- Non-resident owners often select a GBC for cross-border activities, weighing its taxation, advantages, and limitations.
- Ongoing compliance and reporting obligations accompany formation, so plan for both setup and continuing maintenance.
Understanding the Global Business Company (GBC) in Mauritius
The Global Business Company is the principal vehicle through which foreign investors conduct international business from Mauritius, and its defining trait is tax residency: a GBC is treated as a Mauritius tax resident, which opens access to the country's double taxation agreement network. That single feature is what separates it from the Authorised Company and makes it the structure of choice for groups that need treaty protection. The GBC is licensed and supervised by the Financial Services Commission, which positions it within an internationally recognised regulatory framework rather than an offshore one.
This guide explains how a Global Business Company in Mauritius works for a non-resident owner: what it can and cannot do, how it is taxed, what substance and compliance it demands, and what formation involves at a high level. It is most relevant to multinational groups, fund sponsors, and high-net-worth investors using Mauritius as a gateway into African and Asian markets.
Legal Basis and Governing Framework of the GBC
A GBC is incorporated under the Companies Act 2001 and holds a Global Business Licence issued by the FSC under the Financial Services Act 2007. Tax treatment follows the Income Tax Act 1995, while financial reporting sits under the Financial Reporting Act 2004.
Mauritius reformed the regime in 2019. The previous GBC1 and GBC2 categories were replaced with a single Global Business Licence, and the old Deemed Foreign Tax Credit was abolished in favour of a substance-linked partial exemption, aligning the framework with OECD BEPS standards.
Two bodies share oversight of your company. The FSC regulates the licence and the conduct of global business, and the Mauritius Revenue Authority (MRA) handles tax.
The Act sets out what "management and control" in Mauritius means in concrete terms, including at least two resident directors, a principal bank account held locally, accounting records kept at the registered office, and audited financial statements prepared in Mauritius. These conditions matter because they determine whether your company genuinely qualifies for the residence and treaty benefits it claims.
Confidentiality has a statutory footing as well: disclosing confidential information about a GBC without FSC permission is an offence carrying both imprisonment and a fine.
Mauritius Company Incorporation in Mauritius
Set up your company in Mauritius with Expanship handling registration end to end.
Defining Features and Characteristics of a GBC
A GBC has separate legal personality, with the same legal capacity as a natural person. In its most common form, the limited company, shareholder liability is capped at the value of shares subscribed, and the firm's obligations remain its own.
The vehicle is built for business conducted predominantly outside Mauritius. Domestic activity is off-limits except where incidental and necessary to the company's own operations.
Several structural points matter to a foreign owner:
- It accesses the Mauritius treaty network, with over 45 double taxation agreements covering partners across Africa, Asia, and Europe.
- It can be a locally incorporated company or the registered branch of a foreign company, and may migrate domicile while continuing as a Mauritius GBC where the other jurisdiction permits.
- Registers of directors and shareholders are not public; that information does not appear in public sources.
- There are no foreign exchange controls, so capital moves freely in and out.
While a GBC may also take the form of a partnership or trust, the limited company is the structure foreign investors use most.
Ownership, Shareholders, and Share Capital
A GBC requires a minimum of one shareholder, who may be a non-resident. Ownership can be entirely foreign, and there are no nationality restrictions.
Shareholders may be individuals or corporate entities, resident anywhere. Holding companies and investment vehicles are equally acceptable as owners.
On capital, the regime is flexible. There is no statutory minimum, though around USD 1,000 is commonly advised, and share capital may be denominated in any currency other than the Mauritian Rupee.
The company can issue multiple share classes and hold a wide range of assets, including subsidiaries, real estate, debt instruments, and intellectual property. Records of all GBCs are classified and closed to public inspection.
Mauritius Ongoing Compliance in Mauritius
Keep your Mauritius entity compliant with filings, returns, and statutory obligations.
Management, Directors, and Substance Requirements
Substance is the practical core of the GBC. To be managed and controlled from Mauritius, and therefore to keep its tax residence and treaty access, a GBC must meet conditions that go beyond a registered address.
Director and officer requirements include the following:
- At least two directors who are individuals resident in Mauritius, exercising genuine independent judgement and participating in board decisions.
- A locally qualified company secretary.
- A registered office in Mauritius, provided by a licensed management company or a law firm where the company has no premises of its own.
Every GBC must be administered by a firm holding a Management Company licence from the FSC. This is not optional: applications and ongoing administration run through that licensee.
Adequate substance means the company's place of effective management is in Mauritius, its core income-generating activities are carried out in or from Mauritius, board meetings are held there, the principal bank account is maintained there, and accounting records are kept and audited locally. Expenditure must be proportionate to the company's activity.
Treaty benefits and the partial exemption both depend on real management and control in Mauritius. A nominal presence without genuine local activity puts both at risk.
Certain activities can be outsourced to third-party providers under the Income Tax Regulations 2019, provided the work is performed in Mauritius, monitored adequately, and not double-counted by several companies relying on the same provider.
Common Uses and Who Chooses a GBC
The GBC serves a defined set of cross-border functions, almost all directed at investment and trade outside Mauritius. It is widely used by multinational groups, private equity and venture capital sponsors, fund managers, and high-net-worth investors.
Typical applications include:
- Holding companies for subsidiaries across Africa, India, and Asia, structured to optimise dividend flows and reduce withholding taxes through applicable treaties.
- Investment funds, including private equity, hedge funds, and collective investment schemes targeting African and Asian markets, where Mauritius is a recognised fund domicile.
- Intellectual property holding and licensing, with qualifying royalty income potentially benefiting from the partial exemption subject to substance.
- Group treasury and intra-group financing, helped by the absence of exchange controls.
- Cross-border consulting and services firms invoicing international clients through a regulated Mauritian entity.
- Operational headquarters coordinating activity across Africa, the Indian Ocean, and Asia.
The boundaries are firm. A GBC cannot do business with Mauritius residents or run domestic operations, and without separate licensing it cannot conduct banking, insurance, or securities activities. Where both domestic and international business are needed, a separate domestic company is the answer.
Mauritius Mauritius Incorporation Pricing
See transparent pricing to incorporate and maintain a company in Mauritius.
Taxation of the GBC in Mauritius
A GBC is taxed at a flat 15% on chargeable income, but the effective rate is usually far lower. Where substance conditions are met, an 80% partial exemption applies to qualifying income such as foreign dividends and interest, bringing the effective rate on that income to 3%.
The exemption is linked to substance rather than to where income arises, which is what keeps it compliant with OECD and EU expectations. A company cannot both claim the 80% exemption and credit actual foreign tax on the same income; you choose the more favourable route.
Several features make the GBC effective as a holding and trading vehicle:
| Item | Treatment |
|---|---|
| Headline corporate rate | 15% on chargeable income |
| Qualifying foreign dividends and interest | 80% partial exemption, 3% effective rate (subject to substance) |
| Exports of goods | 3% on chargeable income from qualifying export trade |
| Capital gains on shares and securities | No capital gains tax |
| Dividends to non-resident shareholders | No withholding tax |
| VAT | Not required if all activities are outside Mauritius |
To claim treaty benefits abroad, a GBC applies to the MRA for a Tax Residency Certificate, the document counterparty jurisdictions look for. The treaty network covers 46 countries.
Two levies affect larger companies. The Corporate Climate Responsibility Levy of 2% on chargeable income applies, effective from the year of assessment commencing 1 July 2024, to companies with turnover above MUR 50 million. The Fair Share Contribution, in force from 1 July 2025 to 30 June 2028, does not apply to Global Business Licence holders.
Because the effective rate depends on the type of income, the structure, and the relevant treaty, a tailored analysis should precede any decision.
Key Compliance and Reporting Obligations
A GBC carries a heavier compliance burden than a plain domestic company, and renewal of the FSC licence is the obligation that most directly affects its ability to operate.
The recurring duties for a foreign-owned GBC are:
- FSC licence renewal, effective from 1 July 2025 by 30 June each year, with no late renewals permitted. The annual fee is USD 1,950 when paid on time, rising to USD 2,440 within 15 days of lapse; reinstatement after lapse needs FSC approval and attracts a USD 500 fee plus USD 300 per month.
- Audited financial statements prepared under IFRS, audited by a local auditor, filed with the FSC within six months of the financial year-end.
- Annual income tax return to the MRA within six months of the year-end, with Advance Payment System quarterly returns for companies above MUR 10 million turnover.
- Annual return to the Registrar of Companies under the Companies Act 2001, each calendar year after the year of incorporation.
- Beneficial ownership records, kept current and available to the regulator.
- CRS and FATCA reporting, plus AML obligations under the Financial Intelligence and Anti-Money Laundering Act and related law.
Penalties are real. Failure to file the annual return can bring a fine of MUR 20,000 or more, and persistent non-compliance can lead the Registrar to strike the company off the register.
Advantages and Limitations of the GBC
The case for a GBC rests on treaty access combined with a credible, supervised structure. The constraints are mostly cost and the prohibition on domestic business.
Advantages
- Tax residence with access to more than 45 double taxation agreements.
- No capital gains tax on disposals of shares, securities, or investment assets, which suits exit and holding strategies.
- No withholding tax on dividends paid to non-resident shareholders.
- Free movement of funds, with no exchange controls.
- Non-public registers of directors and shareholders.
- A fully audited, regulated framework that gives banks and counterparties confidence.
Limitations
- No domestic business beyond incidental activity, and no banking, insurance, or securities work without separate licensing.
- Higher running costs than other entities, driven by the licence, local directors, secretarial services, and audit.
- Bank onboarding usually takes 4 to 8 weeks and demands full KYC documentation.
- Domestic-source income does not qualify for the partial exemption.
- Tax benefits depend on meeting substance and eligibility conditions, so the actual rate varies by case.
As a guide to scale, first-year formation typically falls in the region of USD 5,000 to USD 12,000 depending on complexity, while annual costs cover the FSC renewal, registered agent and office, accounting and audit, secretarial work, and tax return preparation. Confirm current figures against the official FSC schedule or with Expanship before budgeting.
A Brief Overview of GBC Formation
Formation runs through a licensed management company; a GBC cannot be set up directly. The detailed step-by-step process is covered in a separate guide, so what follows is the outline.
- Reserve the company name with the Registrar of Companies, accompanied by an English or French translation if the name is in another language.
- File the FSC application through the management company, with the constitution, identity documents for directors and shareholders, and a business plan.
- Receive the FSC Letter of Intent, a conditional approval subject to incorporation and conditions being met.
- Incorporate at the Registrar of Companies, which issues the Certificate of Incorporation.
- Obtain the formal Global Business Licence from the FSC.
- Register with the MRA for a Tax Account Number and apply for the Tax Residency Certificate.
- Open the principal bank account with a Mauritius-licensed bank.
On timing, incorporation itself usually takes a few business days, while the FSC licence review commonly runs 4 to 8 weeks; an uncomplicated structure with an expeditious regulator can complete faster. The KYC pack the management company collects typically includes certified passports, proof of address, CVs, bank references, and a business plan with three-year projections and a description of expected financial flows.
The FSC's licensing and fees rules have been amended several times. Verify all government and licence fees against the current official FSC schedule at the time you apply.
Conclusion
A GBC gives a foreign investor a tax-resident, regulated Mauritius entity with treaty access, no capital gains tax, and free repatriation of profits, in exchange for genuine local substance and a real compliance commitment. It rewards groups that conduct meaningful international business through Mauritius and will not suit anyone seeking a passive shell or domestic trade. The economics turn on the type of income and the treaties involved, so the structure deserves a tailored review before you commit. Used properly, it remains a practical base for investment into Africa and Asia.
How Expanship Can Help Your Business in Mauritius
Expanship sets up and administers Global Business Companies in Mauritius, acting through the licensed management company channel that every GBC application requires, and supports the wider needs of a foreign-owned entity once it is running.
- GBC incorporation and FSC licence application
- Registered agent, registered office, and resident directors
- Tax registration with the MRA and Tax Residency Certificate support
- Ongoing compliance, licence renewal, and regulatory filings
- Accounting, IFRS financial statements, and audit coordination
- Introductions to Mauritius-licensed banks for account opening
To discuss your structure and next steps, contact Expanship Mauritius.
Frequently Asked Questions
Yes. A GBC is a Mauritius tax resident, which is what distinguishes it from the Authorised Company and gives it access to the country's double taxation agreements. It can apply to the MRA for a Tax Residency Certificate to claim treaty benefits in counterparty jurisdictions.
No, beyond activities that are incidental and necessary to its own operations. The vehicle is designed for business conducted predominantly with non-residents, so if you also need domestic trade, a separate domestic company is the appropriate route.
The headline rate is 15%, but qualifying foreign dividends and interest can benefit from an 80% partial exemption, giving an effective rate of 3% where substance conditions are met. Qualifying goods exports are also taxed at 3%, and there is no capital gains tax on disposals of shares and securities.
At least two, and they must be individuals resident in Mauritius who take a genuine part in decision-making. This requirement is part of the management and control test that supports the company's tax residence and treaty access.
A GBC must renew its FSC licence by 30 June each year, file IFRS audited financial statements within six months of its year-end, submit an annual tax return to the MRA, file its annual return with the Registrar of Companies, and meet CRS, FATCA, and beneficial ownership requirements. The on-time annual licence fee is USD 1,950, effective from 1 July 2025.
Incorporation at the Registrar usually takes a few business days, while the FSC licence review commonly runs about 4 to 8 weeks. Plan separately for bank account opening, which typically takes a further 4 to 8 weeks and requires full KYC documentation.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
