Category 1 Global Business Licence (GBC1)

Mauritius Global Business Licences

Mauritius offers two types of offshore companies to international investors, the Global Business Licence Category 1 (GBL1) and Global Business Licence Category 2 (GBL2). The main difference lies in the area of taxation.

While a GBL2 company is not taxable in Mauritius, a GBL1 company is liable to tax on its income at a flat rate of 15%. However, a GBL1 company is entitled to the higher of a deemed foreign tax credit of 80% on its foreign source income or actual foreign tax suffered. This effectively reduces the tax liability of a GBL1 company to a maximum of 3%. This resulting tax liability may be reduced to less than 3% and possibly nil depending on other allowable tax deductions or actual foreign tax suffered.

GBL1 Company

A GBL1 is governed by the Companies Act 2001 and The Financial Services Act 2007. This company is mainly used for investment in countries with which Mauritius has a tax treaty, thus conferring various fiscal benefits such as reduced withholding tax on dividends, interest and royalties and no capital gains tax.

A GBL1 can carry out any business activity such as asset management, credit finance, custodian services (non-CIS), distribution of financial products, factoring, leasing, occupational pension schemes, pension fund administration, pension scheme management, retirement benefits schemes, superannuation funds, registrar and transfer agencies, treasury management and such other financial and non-financial activities as may be specified by the FSC.

GBL1 approved activities

Financial Services Activities

  • Aircraft financing and leasing
  • Assets/Fund Management
  • Consultancy/Financial/Employment services
  • Pensions Fund
  • Insurance

Non-financial Services Activities

  • Information and Communication Technology services
  • Logistics and Marketing
  • Operational headquarters
  • Trading
  • Shipping and Ship management
  • Licensing and Franchising
  • Other business activities, subject to FSC approval

A GBL1 company can be considered resident in Mauritius and benefits from the network of Mauritius tax treaties.

To benefit from the tax treaty network, a GBL1 company should demonstrate that it is being managed and controlled from Mauritius and obtain a Tax Resident Certificate from the Mauritius Revenue Authority.

GBL1 Company (Tax Resident – Treaty Access)
General
Type of entity GBL1
Type of law Hybrid
Shelf company availability No
Corporate Taxation Varies from 0% to 3% (maximum)
Double taxation treaty access Yes
Share Capital or Equivalent
Standard currency US$/GBP/EURO
Permitted currencies Any except Mauritius rupees
Minimum paid up 1.00
Directors
Minimum number 2
Local required Yes, but 2 Mauritius resident directors required for
tax treaty access
Publicly accessible records No
Location of meetings Anywhere, but in Mauritius for treaty access
Shareholders
Minimum number 1
Publicly accessible records No
Company secretary
Required Yes
Local or qualified Local and qualified
Accounts
Requirement to prepare Yes
Audit requirements Yes
Requirement to file accounts with
FSC
Yes
Publicly accessible accounts No
Other
Requirement to file annual return No
Re-domiciliation permitted Yes

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