The GBC is registered under the Companies Act 2001 and licensed by the Financial Services Commission. It is mainly used for Financial Services business (subject to additional licenses) and for investment holding activities especially when income from overseas is mainly in the form of dividends, interest, and capital gains. It is eligible for benefits from the network of Double Taxation Agreements (DTA) thus making it an effective corporate vehicle for international tax planning.
Financial services business include:
- Asset management
- Credit finance
- Custodian services
- Distribution of financial products
- Custodian services
- Factoring
- Leasing
- 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 Global Business Corporation is required to establish substance and be effectively managed and controlled in Mauritius. Therefore, as per the governing legislation, the GBC shall, at all times, adhere to the following conditions:
- Carry out its core income generating activities in, or from, from Mauritius by:
- employing, either directly or indirectly, a reasonable number of suitably qualified persons to carry out the core activities, and
- having a minimum level of expenditure, which is proportionate to its level of activities;
- Be managed by controlled from Mauritius;
Be administered by a Management Company;
- Has at least 2 directors, resident in Mauritius, of sufficient calibre to exercise independence of mind and judgment;
- Maintains, at all times, its principal bank account in Mauritius;
- Keeps and maintains, at all times, its accounting records, at its registered office in Mauritius;
- Prepares its statutory financial statements and causes such financial statements to to be audited in Mauritius; and
- Provides for meetings of directors to include at least 2 directors from Mauritius.
When determining what is intended by “a reasonable number of suitably qualified persons” and “a minimum expenditure which is proportionate to its level of activities” the FSC will make the assessment on a case by case basis and will look at the specific circumstances of each GBC. In doing so, the FSC will refer to the indicative guidelines as set out in the following table:
Category
|
Sub-category
|
Minimum Annual Expenditure (USD)
|
Minimum Employment in Mauritius (Direct or Indirect)
|
Non-Financial
|
Investment Holding (excluding IP rights) (*note 1)
|
12,000
|
No minimum employment specified
|
Non-Investment Holding
|
15,000
|
If annual turnover is:
- Less than USD 100m: minimum 1
- More than USD 100m: minimum 2
|
Financial |
CIS Manager / Asset Manager
|
30,000
|
If assets under management are:
- Less than USD 100m: minimum 1
- Between USD 100m and USD 500m: minimum 2
- More than USD 500m: minimum 3
|
Institutions (*note 2)
|
100,000
|
If annual turnover is:
- Less than USD 50m: minimum 1
- Between USD 50m and USD 100m: minimum 2
- More than USD 100m: minimum 3
|
Intermediaries (*note 3) |
30,000
|
1 |
Others
|
25,000
|
1 |
*1 GBCs holding IP Rights will be required to demonstrate that they have incurred expenditure in Mauritius which is proportionate to the research and development of the relevant IP Rights.
*2 E.g. Insurance, Leasing, Credit Finance
*3 E.g. Investment Adviser, Insurance Broker, Insurance Agent.