The GBC is mainly used for Financial Services business (subject to additional licenses), international trading and for investment holding activities especially when income from overseas is principally in the form of dividends, interest, and capital gains.
A GBC is tax resident in Mauritius and may apply for a Tax Residence Certificate (TRC) from the Director General of the MRA should this be required by the tax authorities in the jurisdiction in which the company is conducting its business.
Investors may benefit from an extensive network of double taxation treaties (DTAs). GBCS wishing to benefit from a DTT must obtain a TRC issued by the MRA. The TRC is generally issued within a period of seven days from the date of application, provided that the person has submitted the return required under the ITA 1995.
The GBC may also conduct business in Mauritius provided that the majority of its transactions is done outside of Mauritius.
Substance Requirement of GBCs
It is very important to note that the GBC is required to establish substance in Mauritius. Therefore, as per the Financial Services Act, the GBC should, at all times, satisfy the following conditions:
In order for the GBC to be managed and controlled from Mauritius, it should meet the following conditions:
Mauritius offers an attractive tax regime for companies looking to do business in Africa and Asia. The country's favorable tax rates, partial exemptions, and double tax treaties make it an ideal destination for foreign investors.
In Mauritius, the headline tax rate for most tax resident companies is 15%. However, companies engaged in the export of goods are taxed at a lower rate of 3%. Certain types of income or activities may qualify for a partial exemption of 80%, subject to meeting the economic substance requirements. The partial exemption can effectively bring the tax rate down to 3%. The following types of income or activities are eligible for the partial exemption of 80%:
Foreign-source dividend income may be eligible for partial exemption under simplified conditions. To qualify for an 80% exemption on such income, companies must meet the following requirements:
To qualify for partial exemption on specified categories of income other than dividend in Mauritius, a company must satisfy the following three key conditions:
As per the Financial Intelligence and Anti-Money Laundering Act 2001 (“FIAMLA”) and the FIAMLA Regulations 2018, the Company is required to maintain on file:
Receipt of completed and signed application questionnaires and certified true copies of verification documents*
Compliance verifications and client acceptance procedures are undertaken. Upon approval of the Compliance Unit, the proposed company name is sent to the Registrar of Companies (“RoC”) for reservation.
Company formation and Annual Domiciliation invoice is issued for settlement.
Upon receipt of the Notice of Name Reservation from the RoC and settlement of our fees in full, the Consent of Statutory Forms , namely the Consent of Director Form and Consent of Shareholder Form, are for signature respectively by the Non-Resident Director(s) and the Shareholder(s).
On-line submission of application and statutory forms to the RoC .
As soon as the RoC incorporates the company, the application for licensing together with the Certificate of Incorporation are submitted to the Financial Services Commission (FSC) through its online application portal.
Licence issued the FSC upon the Company meeting all criteria as per The Financial Services (Miscellaneous Provisions) Act 2020.
GBC (Non-Financial Services Business): : 7 to 10 days
AC: 5 to 7 days
NOTE: This timeline is indicative. It has been prepared based on the assumption that procedures will be running smoothly. Imara Trust cannot be held responsible for delays by the local Authorities. Following the licensing of the Company, the first Board Meeting will be held. Immediately thereafter, the application for bank account will be sent. The bank account is generally opened within 4 days.