The Mauritian Global Business regime is currently undergoing certain changes aimed at enhancing the attractiveness and competitiveness of the Mauritius International Financial Centre. These changes involve the harmonisation of the fiscal regime for Domestic Companies and Global Business Companies. There are now two types of company available for international business:
– The GBC is the type of vehicle used for international investment (often where tax treaty benefits are available) and/or where the entity is to be an investment fund. It can also be used for operating activities. The GBC has replaced, with effect from 1 January 2019, the old GBC1 and no further GBC1 licences will be issued by the Financial Services Commission (FSC). The GBC is a re-modelled GBC1 and GBC1s existing on 31 December 2018 will automatically convert to GBC status. The restrictions that existed on the extent to which a GBC1 could conduct dealings in Mauritius have been removed for the GBC. A resident Mauritian company or partnership which is majority held by a non-resident and which conducts the majority of its business outside Mauritius will be required to obtain a GBC licence from the FSC and to do so through a duly appointed management company.
– The Authorised Company is the type of vehicle typically used for entrepreneurial companies and for trading and consulting activities and it can carry out any activity except banking, financial services, investment funds and nominee services. It will not access Mauritius’ tax treaty network. The Authorised Company was introduced with effect from 1 January 2019 to replace the GBC2, and it can carry out all the activities that the GBC2 was able to carry out. Like the GBC2 before it, the Authorised Company is able to avail itself of administration services provided by a management company in Mauritius. An Authorised Company must be majority foreign-owned, conduct its business principally outside Mauritius and have its central management and control outside Mauritius, which will allow it to be treated as non-resident and, therefore, not liable to income tax in Mauritius.