Key Takeaways
- Residence status is the core divide: a GBC is treated as tax-resident and can access double taxation treaties, while an AC is not.
- Substance and reporting obligations are heavier for a GBC, which affects ongoing cost and the management structure you must maintain.
- Privacy and public disclosure differ between the two, so weigh confidentiality needs alongside treaty access when choosing.
- Your intended use case and owner profile should drive the decision, with formation timelines and cost as secondary factors.
Choosing Between a GBC and an Authorised Company in Mauritius
For a foreign owner structuring business through Mauritius, the first real decision is rarely whether to use the jurisdiction at all, but which of its two non-resident vehicles fits the plan: the Global Business Company (GBC) or the Authorised Company (AC). Both are overseen by the Financial Services Commission under the Financial Services Act 2007, and both are built for activity conducted predominantly outside the country.
The two diverge sharply on tax residence, treaty access, substance, and cost. This article compares them on the same decision points and ends with criteria you can apply to your own situation.
It is most relevant if you are a non-resident investor or adviser weighing whether you need Mauritius tax residency and treaty benefits, or simply a tax-neutral holding and trading entity with management based abroad.
What Each Vehicle Is: A Quick Recap of the GBC and the AC
A GBC, formerly the GBC1, is incorporated under the Companies Act 2001 and holds a full Global Business Licence issued by the regulator. It is a Mauritius tax resident, taxed at 15% with a partial exemption system, and it is the only one of the two with access to the country's network of double taxation treaties.
The AC works differently. It is registered with the regulator rather than licensed, and it is treated as non-resident, conducting its business outside Mauritius without treaty access.
The current shape of both vehicles dates from January 2019. That reform abolished the old GBC2 category, and companies holding a GBC2 licence had to apply instead for authorisation as an AC, which became the country's pure offshore vehicle for businesses that do not need tax residency or treaties.
An AC can pursue most commercial activities, including international trading, private asset holding, and consulting. It cannot, however, carry on banking, financial services, investment funds, or nominee services, which remain the territory of licensed structures such as the GBC.
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Legal Personality, Residence Status and Liability
Both vehicles are companies incorporated under the Companies Act 2001, with separate legal personality and shareholder liability limited to the value of shares held. Each must appoint a licensed management company as its registered agent, and neither may issue bearer shares.
The decisive difference is residence. A GBC is tax resident in Mauritius and may apply to the Director General of the Mauritius Revenue Authority (MRA) for a Tax Residency Certificate when a treaty partner requires proof of that status.
An AC is structured to sit outside the tax net. To qualify, it must be majority-owned or controlled by a non-citizen of Mauritius, conduct its business principally abroad, and keep its central management and control outside the country.
Meeting those conditions makes the AC non-resident, and so it is not liable to income tax in Mauritius on foreign-source income. The residence line, more than anything else, drives every downstream difference between the two.
Ownership, Membership and Management Structure
On capital and shareholders the two vehicles are nearly identical. Each needs only one shareholder, individual or corporate and of any residence, no minimum capital is fixed, and share capital may be denominated in any currency other than the Mauritian Rupee.
Where they part company is the board. An AC offers genuine flexibility, allowing a single director, resident or non-resident, with management and control expected to sit abroad.
A GBC carries a heavier requirement: at least two directors resident in Mauritius, of sufficient calibre to exercise independent judgement, plus a qualified company secretary. This reflects the substance the licence demands.
| Feature | GBC | AC |
|---|---|---|
| Minimum shareholders | 1 (resident or non-resident) | 1 (resident or non-resident) |
| Minimum directors | 2 resident in Mauritius | 1 (resident or non-resident) |
| Company secretary | Required | Not mandated as for a GBC |
| Registered agent | Management company | Management company |
| Nominee shareholders | Permitted, with UBO disclosure | Beneficial ownership recorded, not public |
Beneficial ownership rules apply to both. Every company records its beneficial and ultimate beneficial owners in its share register, and owners must declare their status in writing and report changes. For companies incorporated before 30 June 2025, the recordkeeping requirements introduced by recent Companies Act amendments must be met by 30 June 2026.
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Taxation and Access to Double Taxation Treaties
Tax is where the choice usually settles. A GBC is liable to corporate tax at 15% on its tax-adjusted income, but it can claim a foreign tax credit or, where substance conditions are satisfied, a partial exemption of 80% to 95% on qualifying income.
That exemption can bring the effective rate on qualifying foreign-source income down to roughly 3%. The benefit is conditional: it depends on the nature of the income, the licensed activity, and meeting the substance tests in full.
Treaty access belongs to the GBC alone. Only a tax resident entity can use the Mauritius double taxation agreement network, which spans 46 signed treaties, and a Tax Residency Certificate from the MRA is the document needed to claim those benefits abroad.
The AC stands on the other side of this line. It is non-resident, taxed at 15% only on Mauritius-source income, and exempt from tax on foreign-source income, but it has no access to any treaty.
| Dimension | GBC | AC |
|---|---|---|
| Tax residence | Resident | Non-resident |
| Headline rate | 15% | 15% on Mauritius-source income only |
| Effective rate on qualifying foreign income | As low as ~3% with partial exemption | Foreign-source income not taxed in Mauritius |
| Treaty (DTA) access | Yes, with TRC | None |
| VAT | Not required if all activity is offshore; registration applies above MUR 6m taxable supplies in Mauritius | Exempt |
Two newer measures matter for larger groups. A Qualified Domestic Minimum Top-up Tax applies from the year of assessment commencing 1 July 2025 to Mauritius resident entities within multinational groups of EUR 750 million or more in consolidated revenue where the local effective rate falls below 15%.
The Fair Share Contribution, effective 1 July 2025 to 30 June 2028, does not apply to companies holding a Global Business Licence. Neither vehicle faces capital gains tax, since Mauritius levies none.
An AC is taxed where it is effectively managed and controlled. If that place is your home country, foreign-source income may be taxable there, and holders in jurisdictions with controlled foreign company rules should plan accordingly.
Privacy, Confidentiality and Public Disclosure
Both vehicles offer a high degree of confidentiality. Director, secretary, and shareholder records held by the regulator are treated as confidential and are not released to third parties without the company's consent, and the ultimate beneficial owner is not made public.
Beneficial ownership is collected by the authorities under the anti-money-laundering framework, but it is not published. The Financial Services Act protects this information, with unauthorised disclosure by regulator staff being an offence and only narrow exceptions, such as a court order in a money-laundering or drug-trafficking matter.
A public online search at the Companies and Business Registration Department confirms that a company exists and shows core details, but the underlying ownership and officer records stay closed. This applies equally to both structures.
One practical difference is reputational, not legal. Some banks and counterparties extend more credibility to a GBC, which holds a full licence, than to an AC, which is only registered; this can matter when opening accounts or contracting internationally.
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Formation Process, Timelines and Cost
Both routes run through a licensed management company, which prepares and files the application on your behalf. The KYC pack is broadly the same for each: certified passports and proof of address for all directors, shareholders, and ultimate beneficial owners, corporate documents for any corporate shareholder, a business plan, and a source of funds declaration.
A GBC application is the more involved of the two. It requires a detailed business plan, a legal certificate from a Mauritian lawyer, due diligence on directors and beneficial owners, and submission to the regulator through the management company on the prescribed form.
An AC application is lighter. The management company files ownership details and a brief business plan with the regulator at incorporation, and submits the incorporation documents to the Registrar in the approved form signed by the registered agent.
Timelines reflect that gap. Expect an AC to form in roughly two to four weeks, with the underlying incorporation taking only a handful of working days. A GBC typically reaches licensed status in about four to six weeks, since the licence application follows incorporation.
On cost, state the statutory fees with care and confirm current figures before you commit:
- The annual government fee for a GBC and an AC differs significantly, with the GBC fee being the higher of the two. Both are set out in the FSC Consolidated Licensing and Fees Rules; confirm the current amounts against that schedule or with your management company before budgeting.
- First-year set-up combines the regulator's fee, the Registrar's incorporation fee, and the management company's formation charge. An AC sits at the lower end of these components; a GBC is materially higher, particularly once resident directors and office costs are added.
- Ongoing annual maintenance is higher for a GBC than for an AC, driven mainly by substance: resident directors, local office, staff, and audit.
Whatever the month of incorporation, the licence or authorisation runs to 30 June, with the first fee payable pro rata; renewal then covers a full 1 July to 30 June year. Fees paid more than a month late attract a 25% surcharge, with further monthly charges thereafter.
Ongoing Compliance, Substance and Reporting Obligations
This is where the running difference between the two becomes clearest. A GBC must demonstrate real economic substance in Mauritius to keep its licence and to use the partial exemption.
The substance conditions are specific and continuous. Core income-generating activities must be carried out in or from Mauritius, at least one suitably qualified person must be employed full-time on site, a physical office must be maintained, local expenditure must be proportionate to activity, at least two resident directors must be appointed, and the principal bank account must sit with a Mauritius-licensed institution.
These rules were formalised after the country's OECD BEPS commitments and the EU Code of Conduct standards, and the regulator enforces them through the licensing framework. A GBC that meets them can obtain its Tax Residency Certificate, which the MRA reviews annually.
Reporting for a GBC is full. Audited financial statements prepared under IFRS go to the Registrar within six months of the balance sheet date, a tax return goes to the MRA on the same timeline, and audited accounts are also filed with the regulator. Late filing carries a daily fine of USD 10 until accounts are submitted, capped at USD 5,000.
An AC carries a much lighter load. It has no prescribed economic substance requirements, though it must keep a registered agent and a registered office in the country, and it cannot be treated as a hollow shell.
Its filings are correspondingly simpler. An AC files an income return with the MRA within six months of year-end and lodges a financial summary, rather than a full audited set, with the Registrar; an audit is required only where annual turnover exceeds MUR 100 million.
Two obligations bind both vehicles. Each must file an annual return with the Registrar, and any change of director or shareholding must be filed within 28 days under the Companies Act 2001, with the Registrar's annual fee payable by 10 January.
Typical Use Cases and the Ideal Owner for Each Vehicle
The GBC earns its extra cost when treaty access is the point. It suits international holding companies channelling investment into treaty partners such as India, China, or African markets, fund and private equity platforms, and groups that need a Tax Residency Certificate to reduce withholding tax on dividends, interest, and royalties.
Choose a GBC if you need Mauritius tax residency and treaty benefits and can support the substance that goes with them: resident directors, a local office, local staff, and audited accounts. The vehicle rewards owners with the scale and budget to maintain that footprint.
The AC fits a different profile. It is built for entrepreneurial companies running international trade, e-commerce, consulting, private asset holding, and invoicing, where no treaty benefit is sought and management genuinely sits abroad.
Choose an AC if your control is exercised outside Mauritius and you want a tax-neutral, lower-cost entity without licensing and substance overheads. Remember that the AC is tax-neutral in Mauritius, not tax-free worldwide, and that controlled foreign company rules in your own country can still apply.
One door is closed to the AC. It cannot conduct banking, insurance, securities, fiduciary, fund, or trustee work, nor any gambling business; activities of that kind require a licensed structure such as the GBC.
It is possible to start as an AC and convert to a GBC later. That step means filing a licence application with the regulator, evidencing sufficient substance, and meeting the full GBC criteria, a process that takes several weeks and adds licence and compliance costs.
Conclusion
The decision turns on a single question: do you need Mauritius tax residency and treaty access, or not? If you do, and you can carry the substance and cost, the GBC is the structure that delivers a Tax Residency Certificate, treaty benefits, and an effective rate that can fall to around 3% on qualifying foreign income. If you do not, the AC gives you a tax-neutral, lighter, lower-cost vehicle for trading, holding, and consulting managed from abroad. Match the vehicle to how and where your business is genuinely run, then confirm the current fees and substance expectations before you file.
How Expanship Can Help Your Business in Mauritius
Expanship advises foreign owners on whether a GBC or an AC fits their plan, then handles the formation, licensing or registration, and the substance and reporting that follow. The same team supports the wider needs of a foreign-owned entity in the jurisdiction once it is live.
- Incorporation of your GBC or Authorised Company through a licensed management company
- Registered agent and registered office in Mauritius
- Tax registration, TRC applications, and annual return filing
- Ongoing compliance management, including substance evidence and statutory filings
- Accounting, bookkeeping, and audit coordination
- Introductions to banks for account opening
To discuss which structure fits your business, contact Expanship Mauritius.
Frequently Asked Questions
No. Only a GBC, as a tax resident entity, can use the country's network of 46 signed treaties, and it needs a Tax Residency Certificate from the MRA to claim those benefits. An AC is treated as non-resident and has no treaty access at all.
No, it is tax-neutral in Mauritius rather than tax-free globally. An AC pays 15% only on Mauritius-source income and is exempt on foreign-source income, but it is taxable where it is effectively managed and controlled, so income may be taxed in your home country or another jurisdiction.
A GBC must have at least two directors resident in Mauritius who are of sufficient calibre to exercise independent judgement, plus a qualified company secretary. An AC can operate with a single director of any residence, with management and control expected to sit outside Mauritius.
Generally no. An AC files a financial summary rather than a full audited set with the Registrar within six months of its balance sheet date, and a full audit becomes mandatory only where annual turnover exceeds MUR 100 million. A GBC, by contrast, must always file audited financial statements prepared under IFRS.
Yes. You file a licence application with the regulator, demonstrate sufficient economic substance in Mauritius, and meet the full GBC criteria. The process usually takes several weeks and brings additional licence and compliance costs, so plan for it rather than assuming a quick switch.
The AC. Its incorporation and registration typically complete in about two to four weeks, since the application is lighter. A GBC usually reaches licensed status in roughly four to six weeks, because the licence application follows incorporation and involves a fuller review.
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.
