By using our website you consent to all cookies in accordance with our Privacy Policy.

Changes-to Mauritius-Global-Business-Corporation-regime

The enactment of Mauritius Financial (Miscellaneous Provisions) Act 2018 (FMPA 2018) has removed Global Business Corporation Category 1 and 2 licenses (GBC1 and GBC2) since Jan 2019 to be compliant with the OECD/G20 BEPS Project.

Major changes in FMPA 2018 are summarized as below:

  • Rename GBC1 to Global Business Corporation (GBC) and introduce additional substance requirements for GBC;
  • Replace GBC2 with new Authorized Company (AC).

Global Business Corporation (GBC)

A resident corporation whose majority of shares or voting rights or the legal or the beneficial interest held or controlled by a person who is not a citizen of Mauritius conducting or proposing to conduct business principally outside of Mauritius must apply for the GBC.

A GBC is now subject to new requirement of core income-generating activities at all times carried out in 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 in addition to existing enhanced substance requirements as follows:

  1. be managed and controlled from Mauritius; and
  2. be administered by a management company.

Foreign Tax Credit previously applied to GBC1 is removed and replaced with a partial tax exemption of 80% for qualified sources provided that the substance requirements are met.

The qualified sources comprise of:

  • Foreign source dividend provided that it is not allowed as a tax-deductible item in the source country.
  • Foreign source interest income.
  • Profit attributable to a permanent establishment which a resident corporation has in a foreign country.
  • Income derived by a collective investment scheme (CIS), closed-end fund, CIS manager, CIS administrator, investment adviser or assets manager licensed or approved by the Financial Service Commission.
  • Income derived by companies engaged in ship and aircraft leasing.

Transitional provisions:

  • All GBC1 licenses issued on or before 16th Oct 2017 will be grandfathered till 30th Jun 2021, after which they will be deemed to be GBC.
  • All GBC1 licenses issued after 16th Oct 2017 were grandfathered till 31st Dec 2018. They are now deemed as GBC.

Authorised Company (AC)

The Authorised company has replaced GBC2 since Jan 2019. An AC is deemed as “non-resident” for tax purpose, and thus is not subject to income tax in Mauritius.

A company holding Authorized Company license must satisfy the following conditions:

  • Be held or controlled by a person who is not a citizen of Mauritius;
  • Proposes to conduct or conducts business mainly outside Mauritius;
  • Has its place of effective management outside Mauritius.

In order to comply with local regulation, an Authorised company must

  • At all times have a registered agent in Mauritius who shall be a management company;
  • File a financial summary with the FSC every year;
  • File annual tax return with the Mauritius Revenues Authority.

Transitional provisions:

  • All GBC2 incorporated on or before 16th Oct 2017 will be grandfathered till 30th Jun 2021. After that date, the company has the option to convert into the new structure or be dissolved.
  • All GBC2 incorporated after 16th Oct 2017 will be grandfathered till 30th Dec 2018. After that date, the company has the option to apply for the AC license or be dissolved.

If you have any questions regarding the new regime of Global Business sector in Mauritius, please feel free to contact us. We are happy to answer your questions or assist you to assess your case and propose with solutions.

Recent Posts

20 Apr 2021

FAQs – 12 Frequently Asked Questions About Delaware Corporation

You may be confused about corporation types, structures, benefits, annual fees and how to form. These 12 FAQs about Delaware corporation are for you.

Read more
15 Apr 2021

Private Limited Company – An Emerging Form of Business in the UK

Everything you need to know about forming a Private Limited Company in the UK, including the pros and cons, formation requirements, and legal responsibilities.

Read more
16 Apr 2021

Delaware Withholding Tax: What New Employers Should Know

Delaware withholding tax is imposed on wages paid to employees who perform for a company in the state. The employer must pay the amount to the local authority.

Read more
16 Apr 2021

Delaware Franchise Tax And Annual Report: What You Need To Know

Delaware franchise tax is one of mostly-asked topics for any business registered in the state, especially corporations and LLCs. This blog will explain to you.

Read more
7 Apr 2021

How To Form A Delaware Corporation: A Complete Guidance

Forming Delaware corporation is a trending option for most startups in the US. These easy-to-follow steps will guide you on how to set up a Delaware corporation.

Read more
1 Apr 2021

Delaware LLC Annual Fees and Annual Report: How to Stay Compliant

A Delaware LLC need not file an annual report. But it may report on its income. Besides, a Delaware LLC needs to pay two kinds of annual fees for maintenance.

Read more
2 Apr 2021

Top 4 Delaware corporation benefits you should know

Forming corporations in Delaware offers a large number of benefits in taxation, legal process, privacy protection, investor attraction. Read this for details.

Read more
13 Apr 2021

How to Register an LLC in Delaware (in Only 3 Steps)

To register LLC in Delaware, you can follow the 3 simple steps: choose the LLC name, submit an application, and receive the result. Learn more!

Read more
31 Mar 2021

Reasons why you should incorporate in Singapore (2021 updates)

Small in size, enormous in scale – this is the best way to describe Singapore. Let's take a look at reasons why you should incorporate in Singapore with BBCIncorp!

Read more
22 Mar 2021

Uncover Delaware LLCs in 8 questions

Delaware limited liability company is a very common type of business entity for non-US residents. Here’re 8 questions to uncover your curiosity about Delaware LLCs.

Read more
13 Apr 2021

Delaware LLC with its benefits and drawbacks

Why incorporate in Delaware? Along with tons of benefits, Delaware LLC also has some drawbacks. Let’s take a closer look at its advantages and disadvantages!

Read more
10 Mar 2021

Starting a business in Delaware: A guide you can't miss

Starting a business in Delaware might be no easy task. There are requirements that need to be taken into consideration. Let's find out more with BBCIncorp!

Read more