Global Business Company (GBC) in Mauritius
The Global Business Company is the benchmark vehicle for international activities from Mauritius. FSC licence, access to tax treaties, partial exemption: discover the complete framework.
What is a Global Business Company?
The Global Business Company (GBC) is a company incorporated in Mauritius under the Companies Act 2001 and holding a licence issued by the Financial Services Commission (FSC) under the Financial Services Act 2007.
The GBC is the primary vehicle used by international investors wishing to structure their activities from Mauritius. It combines Mauritian tax resident status -- providing access to the network of double taxation agreements -- with a partial exemption regime on foreign-source income, subject to strict economic substance conditions.
The GBC is supervised by both the FSC (financial services regulator) and the Mauritius Revenue Authority (MRA) for tax matters. This dual supervision gives the GBC a high level of credibility with banking partners, commercial counterparties and foreign tax authorities.
Every GBC must be administered by a Management Company (MC) licensed by the FSC. Sunibel Corporate Services, as a licensed MC, is authorised to incorporate, administer and ensure the regulatory compliance of GBCs.
Who is the GBC suited for?
The Global Business Company is suited to a wide range of investor profiles and international activities. Here are the most common use cases.
Holding companies
Holding participations in foreign subsidiaries, with optimisation of dividend and capital gains flows through tax treaties and the absence of capital gains tax on securities.
International trading
Commodity trading, import-export and commercial intermediation between Asian, African and European markets. The geographical position of Mauritius and its access to regional trade agreements (COMESA, SADC) enhance the attractiveness of this structure.
Investment management
Investment funds, collective investment vehicles and private equity structures targeting African and Asian markets. Mauritius is recognised as a structuring platform for investments into India and sub-Saharan Africa.
Intellectual property
Holding, management and licensing of intellectual property rights (trademarks, patents, software). Royalty income received by a GBC may benefit from the partial exemption system, subject to substance conditions.
Group treasury
Centralisation of a multinational group's treasury, intra-group loans and management of international financial flows. The absence of exchange controls in Mauritius facilitates the movement of capital.
Regional headquarters
Establishing an operational headquarters to coordinate activities in Africa, the Indian Ocean or Asia. Mauritius offers an attractive living environment for executives wishing to relocate to Mauritius, with quality infrastructure and a multilingual environment (English, French).
Advantages of the Global Business Company
Access to the treaty network
Mauritius has concluded more than 44 double taxation agreements (DTAs) with countries in Africa, Asia, Europe and the Middle East. These treaties allow the reduction or elimination of withholding taxes on dividends, interest and royalties paid from signatory countries to a Mauritian GBC. Access to this network is conditional on obtaining a Tax Residence Certificate (TRC) issued by the MRA.
Partial exemption system
The Partial Exemption Regime allows GBCs to benefit from an 80% tax credit on certain categories of foreign-source income. The nominal tax rate is 15 %, resulting in an effective rate that can be reduced to 3% subject to conditions. Eligible categories include:
- Foreign-source dividends
- Foreign-source interest income
- Intellectual property income (royalties)
- Income from the provision of services to non-residents
- International trading income (commodity trading)
Important: the benefit of the partial exemption is conditional on meeting economic substance requirements. See our dedicated page on corporate taxation in Mauritius for an overview of the tax framework.
Favourable taxation of capital gains and dividends
Mauritius does not levy capital gains tax on the disposal of securities. Furthermore, there is no withholding tax on dividends paid by a Mauritian company to its shareholders, whether resident or non-resident. This combination is particularly advantageous for international holding structures.
International credibility and compliance
The GBC benefits from the supervision of the FSC, an internationally recognised regulator. Mauritius is on the EU whitelist, compliant with OECD standards and a member of the FATF (via ESAAMLG). This compliance enhances the credibility of the structure with correspondent banks, commercial partners and tax authorities.
Favourable business environment
Free movement of capital, absence of exchange controls, hybrid legal system (common law and civil code), qualified bilingual workforce, modern digital infrastructure and political stability make Mauritius a conducive environment for international business development.
GBC conditions and obligations
Economic substance requirements
The FSC imposes strict substance requirements on GBCs. These requirements aim to ensure that the company carries out genuine activity from Mauritius and is not an artificial structure. The criteria assessed include:
- Qualified personnel: employment of at least one qualified employee in Mauritius, full-time or through the Management Company
- Physical office: availability of professional premises suited to the activity (the MC's registered office may suffice for certain activities)
- Local expenditure: incurring operational expenditure proportionate to the nature and volume of the activity
- Board of directors: holding board meetings in Mauritius, with at least two Mauritian resident directors
- Strategic decisions: key business decisions must be taken in Mauritius
- Record keeping: all accounting and statutory documents must be maintained in Mauritius
FSC licence
Obtaining and maintaining the FSC licence is a sine qua non condition of GBC status. The licence application requires submission of a detailed business plan, KYC documents of beneficial owners and directors, and evidence of planned substance. The licence must be renewed annually, with payment of the corresponding fees.
Reporting obligations
- Audited annual accounts: prepared in accordance with IFRS standards and audited by an approved firm in Mauritius -- our accounting and compliance service covers all these obligations
- Tax return: filing within 6 months of the financial year-end with the MRA
- Annual Return: annual filing with the Registrar of Companies
- CRS and FATCA filings: automatic transmission of information to partner jurisdictions
- FSC reports: periodic reports on activity, structural changes and significant events
Global Business Company taxation
The tax regime applicable to GBCs is one of the main attractions of Mauritius as an international financial centre. Here are the key elements of the tax framework.
Corporate tax
The nominal corporate tax rate in Mauritius is 15%, applicable to the company's worldwide income. However, the partial exemption system allows a significant reduction for eligible foreign-source income.
For eligible income categories, a deemed foreign tax credit of 80% is applied, bringing the effective rate down to 3%. This mechanism is compliant with OECD and EU guidelines, as it is linked to substance criteria rather than the geographical origin of the taxpayer.
No capital gains tax
Mauritius does not levy any capital gains tax on the disposal of securities (shares, equity interests, bonds). This provision is enshrined in Mauritian tax legislation and applies without any particular conditions.
No withholding tax
There is no withholding tax on:
- Dividends paid by a Mauritian company to its shareholders (resident or non-resident)
- Interest paid to non-residents
- Royalties paid to non-residents
Tax Residence Certificate (TRC)
To benefit from double taxation agreements, the GBC must obtain a Tax Residence Certificate (TRC) from the MRA. This certificate attests to the company's Mauritian tax resident status and is issued annually, subject to meeting substance criteria. The TRC is the key document that foreign tax authorities and banks require to apply reduced treaty rates.
Disclaimer
The tax advantages described above are subject to strict conditions of substance, compliance and eligibility. The effective tax rate varies depending on the nature of the income, the structure of the company and the applicable treaties. A personalised analysis is essential before any structuring decision. The information provided on this page does not constitute tax advice and should not be relied upon as a substitute for the advice of a qualified professional.
GBC incorporation process
Incorporating a Global Business Company follows a rigorous process governed by the Companies Act and the Financial Services Act. Sunibel Corporate Services manages the entire process as a licensed Management Company.
Preliminary analysis and structuring
Assessment of your project, identification of objectives, analysis of the jurisdictions involved and applicable tax treaties. Recommendation on the suitability of the GBC compared to alternatives (AC, domestic company).
Document collection and due diligence
Collection of identity documents, bank and professional references, proof of source of funds and wealth. KYC/AML checks conducted in accordance with regulatory obligations.
Company incorporation
Name reservation, drafting of the constitution, registration with the Registrar of Companies. Obtaining the certificate of incorporation and the BRN (Business Registration Number). Timeline: 2 to 5 business days.
FSC licence application
Preparation and submission of the complete application to the Financial Services Commission: business plan, description of activities, directors' CVs, proof of planned substance, AML compliance declaration. Timeline: 4 to 8 weeks.
Tax registration and TRC
Registration with the Mauritius Revenue Authority, obtaining the Tax Account Number (TAN). Application for the Tax Residence Certificate (TRC) for access to double taxation agreements.
Bank account opening
Selection of the bank suited to the activity profile, preparation of the account opening file, assistance during the meeting with bank officials. See our guide on opening a bank account in Mauritius. Timeline varies depending on the chosen institution (2 to 6 weeks).
Operational set-up
Appointment of officers, first board meeting, implementation of substance (office, personnel, service contracts). Transition to the ongoing administration phase managed by Sunibel Corporate Services.
Documents required for GBC incorporation
Incorporating a GBC requires a comprehensive set of documents, subject to FSC requirements and anti-money laundering obligations. Here is the list of documents generally required.
Identification documents
- Certified copy of the passport of each shareholder and director
- Recent proof of address (less than 3 months old)
- Bank reference from the usual bank
- Professional reference (lawyer, notary or accountant)
- Detailed CV of each proposed director
Activity-related documents
- Detailed business plan including description of activities, target markets and 3-year financial projections
- Organisational chart of the planned structure (ownership, subsidiaries, beneficial owners)
- Description of expected financial flows (nature, origin, destinations)
- Contracts or letters of intent with partners (where applicable)
Compliance documents
- Documented source of funds declaration
- Source of wealth declaration
- Declaration of absence of criminal convictions
- For corporate shareholders: certificate of incorporation, articles of association, register of directors, audited financial statements and KYC documents for each beneficial owner (10% threshold)
All documents must be in English or French. Documents in another language must be accompanied by a certified translation. Copies must be certified by a notary, lawyer or consular authority.
GBC or Authorised Company: which to choose?
The choice between the GBC and the Authorised Company depends on several factors. The comparison table below summarises the main differences between these two structures.
| Criterion | Global Business Company | Authorised Company |
|---|---|---|
| FSC licence | Mandatory | Not required |
| Tax treaties | Access to 44+ DTAs | Not eligible |
| Nominal tax rate | 15% | 15% |
| Partial exemption | Eligible (effective rate of 3% subject to conditions) | Not eligible |
| Economic substance | Substantial requirements | Reduced requirements |
| Annual audit | Mandatory (IFRS standards) | Threshold-based |
| Management Company | Mandatory (FSC-licensed MC) | Mandatory (FSC-licensed MC) |
| Set-up costs | Higher (FSC licence, audit, substance) | More moderate |
| Set-up timeline | 8 to 16 weeks | 3 to 8 weeks |
| Typical profile | Holding, international trading, investment, IP | Simple international activities, international consulting |
This comparison is provided for guidance purposes. The choice between GBC and AC depends on numerous factors specific to each project. Contact us for a personalised analysis.
Frequently asked questions about the GBC
Incorporate your GBC with Sunibel Corporate Services
As a Management Company licensed by the FSC, we support you in the incorporation, licensing and comprehensive administration of your Global Business Company.
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