A Category 1 Global Business Licence company ("GBC1") can either be incorporated locally or be registered as a branch of a foreign company. A foreign company may be re-domiciled and continue as a Mauritian GBC1 if the foreign law so permits.
A GBC1 which demonstrates substance in Mauritius can benefit from Mauritius' tax treaty network. The FSC shall, in determining whether the conduct of business is being managed and controlled from Mauritius, have regard to such matters as it may deem relevant in the circumstances and, in particular, may have regard to whether the company:
- shall have or has at least two directors, resident in Mauritius, of sufficient calibre to exercise independence of mind and judgement;
- shall maintain or maintains at all times its principal bank account in Mauritius;
- shall keep and maintain or keeps and maintains, at all times, its accounting records at its registered office in Mauritius;
- prepare or proposes to prepare its statutory financial statements and causes or proposes to have such financial statements to be audited in Mauritius;
- provides for meetings of directors to include as least 2 directors from Mauritius.
A GBC1 can conduct both financial services and non-financial services. A specific licence is required for different types of "financial services" and "financial services business". "Financial business activities" are defined to include:
- Asset management
- Credit finance
- Custodian services
- Distribution of financial products
- Custodian services
- Occupational pension scheme
- Pension fund administrators
- Pension scheme management
- Retirement benefits scheme
- Superannuation funds
- Registrar and transfer agent
- Treasury management
- Such other financial business activity as may be specified in FSC rules
A corporation for the purpose of a Category 1 Global Business Licence includes a company formed in Mauritius or elsewhere, a trust or a partnership.
A Category 1 Global Business Licence is necessary where the company intends to access Mauritius''s network of tax treaties. A company holding a Category 1 Global Business Licence is subject to Mauritian corporate income tax at the rate of 15%.
The practical effect of the 15% rate is mitigated by the Income Tax (Foreign Tax Credit) Regulations 1996, which provide for a phantom foreign tax credit of 80% of the 15% charged making the effective rate of tax 3%.
There is no Mauritian capital gains tax on the disposal of shares or other assets.
There is no Mauritian dividend or interest withholding tax.