Offshore company in Mauritius: what you really need to know

The term "offshore" in Mauritius: an outdated concept

The term "offshore company" is still commonly used in searches related to Mauritius. It corresponds to a historical reality -- that of former so-called "offshore" regimes that offered untaxed companies, without substance and with minimal transparency. This model no longer exists in Mauritius since the fundamental reforms of 2018-2019.

The Financial Services Commission (FSC) and the Mauritian government carried out a profound transformation of the international financial sector. Mauritius now positions itself as an International Financial Centre (IFC) -- a regulated, transparent international financial centre that complies with global standards. This evolution is not cosmetic: it is accompanied by real requirements in terms of economic substance, tax compliance and international cooperation.

Specifically, the former categories -- "Category 1 Global Business Licence" and "Category 2 Global Business Licence" -- have been replaced by two clearly defined structures:

• The Global Business Company (GBC), a regulated structure holding an FSC licence.
• The Authorised Company (AC), a simplified structure registered with the FSC without a licence.

Both structures are subject to tax at a rate of 15 %, must satisfy compliance and accounting obligations and are supervised by the Mauritian authorities. See our comprehensive guide on corporate taxation in Mauritius for a complete overview.

International structures available in Mauritius

The Global Business Company (GBC)

The GBC is the benchmark structure for international activities in Mauritius. It holds a licence from the Financial Services Commission, which confers several major advantages:

• Access to the network of 44 double taxation agreements signed by Mauritius (India, South Africa, United Kingdom, France, Luxembourg, China, Singapore, etc.).
• Ability to carry out regulated activities: fund management, financial services, insurance, international leasing.
• Eligibility for the Tax Residence Certificate issued by the Mauritius Revenue Authority, essential for the application of treaty provisions.
• Perception of credibility and solidity with banks, commercial partners and foreign tax authorities.

In return, the GBC must demonstrate genuine economic substance in Mauritius: at least two resident directors, board meetings held in Mauritius, premises, qualified personnel and operational expenditure on the territory.

The Authorised Company (AC)

The Authorised Company is a lighter structure, suited to activities that do not require access to tax treaties or the conduct of regulated activities. It does not hold an FSC licence and its substance requirements are reduced. It is typically suited to pure holdings, intellectual property management, international e-commerce or consultancy services to a foreign clientele.

The AC cannot carry out activities in Mauritius, does not benefit from DTAs and cannot obtain a Tax Residence Certificate.

Why Mauritius is no longer considered a "tax haven"

The question comes up regularly: is Mauritius a tax haven? The answer is clearly no, for objective and verifiable reasons:

• FATF compliance: Mauritius is a member of the Financial Action Task Force and ESAAMLG (Eastern and Southern Africa Anti-Money Laundering Group). The country has passed mutual evaluations and has not been on any FATF grey or black list since its removal from the grey list in 2021.
• EU whitelist: Mauritius is on the European Union's list of cooperative jurisdictions in tax matters. This qualification is regularly reassessed and reflects compliance with good tax governance standards.
• OECD standards: Mauritius is a signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and participates in the BEPS Inclusive Framework. The country applies OECD transfer pricing standards and anti-abuse rules.
• Automatic exchange of information (CRS): Mauritius is committed to automatic exchange of financial information with more than 100 jurisdictions under the OECD's Common Reporting Standard.
• Substance requirements: the 2018 reforms introduced genuine economic substance obligations for GBC companies, eliminating the possibility of creating "empty shell" structures.
• Effective tax rate: the standard rate of 15 % is comparable to many European countries (Ireland: 15 %, Hungary: 9 %, Bulgaria: 10 %) and well above that of genuinely offshore jurisdictions (0 % in BVI, Cayman Islands or Bahamas).

Advantages of the Mauritian framework for international investors

While Mauritius does not offer the zero taxation of a traditional offshore jurisdiction, the country presents a set of structural advantages that make it a platform of choice for international structuring:

• 44 double taxation agreements: one of the most extensive networks in Africa, covering Europe, Asia, Africa and the Middle East. A major asset for reducing withholding taxes and optimising flows between jurisdictions.
• Political and institutional stability: stable parliamentary democracy since 1968, peaceful transitions of power, rule of law upheld. A secure environment for investors.
• Dual legal system: based on Anglo-Saxon common law with influences from French civil law, offering flexibility and familiarity to investors from different legal traditions.
• FSC regulation: an independent and recognised regulator that oversees the non-banking financial sector, providing credible supervision in the eyes of international partners.
• Bilingual environment: French and English are commonly used in the business world, a rare feature that facilitates exchanges with both French-speaking and English-speaking investors.
• No exchange controls: free movement of capital, full repatriation of profits, dividends and capital without restriction.
• No capital gains tax: no taxation of capital gains in Mauritius, a significant advantage for holding and investment structures.
• No withholding tax: dividends, interest and royalties paid to non-residents are not subject to any withholding tax.

How to choose between GBC and Authorised Company?

The choice of structure depends on precise criteria related to your project. Here are the main decision elements:

In many cases, the answer is not binary. Some projects combine a GBC for activities requiring treaty access with an AC for ancillary activities. For local activities, a Mauritian local company may also be considered. Our role is to analyse your overall situation to recommend the most efficient architecture. See our comprehensive guide on company formation in Mauritius.

The role of the management company

Every international company in Mauritius -- GBC or Authorised Company -- must be administered by a management company licensed by the FSC. This is not optional: it is a legal requirement enshrined in the Financial Services Act 2007.

The management company plays a central role in the life of your company:

• Incorporation and registration: preparation of constitutional documents, KYC/due diligence procedures, filing with the Registrar and the FSC.
• Corporate secretarial services: maintenance of mandatory registers, drafting of resolutions, organisation of meetings, filing of annual documents.
• Regulatory compliance: monitoring of the company's obligations, CRS and FATCA filings, FSC reports, economic substance monitoring.
• Accounting and taxation: bookkeeping, preparation of financial statements, filings with the Mauritius Revenue Authority, liaison with auditors.
• Interface with authorities: the management company is the official point of contact with the Registrar of Companies, the FSC and the MRA.

Sunibel Corporate Services Ltd is a management company holding a licence issued by the Financial Services Commission of Mauritius. A member of the Probus Pleion group, we offer support that combines local expertise with an international perspective, with offices in Grand Baie and Quatre Bornes and a partner network in Switzerland, Dubai, Luxembourg and Thailand.

Our commitment: to provide you with transparent, professional support that complies with the most demanding international standards. We do not sell "offshore companies" -- we structure sustainable, compliant international operations.