Corporate Clients

The GBC is resident for tax purposes in Mauritius and can thus avail of the Double Taxation Avoidance Agreements Networks of Mauritius.

Uses: Invoicing companies , Property holding royalty and intellectual property company, Service Companies such as: Sales promotion, Debt collection, Treasury management, Accounting functions, Consultancy work, Recruitment, etc.

To establish its residence the GBC, in addition to its place of incorporation is in Mauritius a GBC should demonstrate that managed and controlled is from Mauritius;
a. The Company shall have at least 2 directors, resident in Mauritius, of sufficient calibre to exercise independence of mind and judgement;
b. The Company shall maintain at all times its principal bank account in Mauritius;
c. The Company shall keep and maintain, at all times its accounting records at its registered office in Mauritius;
d. Prepares its statutory financial statements has such financial statements to be audited in Mauritius; and
e. Provides for meetings of directors to include at least 2 directors from Mauritius.
f. Maintain its registered office and all statutory records in Mauritius .
g. Have a local qualified company secretary.
h. Have a local auditor.

In addition, a GBC must carry out its core income generating activities from Mauritius by:

• employing, directly or indirectly, a reasonable number of suitably qualified persons to carry out the core activities; and
• having a minimum level of expenditure proportionate to its level of activities.

Accounting, tax and audit requirements for GBC

The flat tax rate for GBC companies is 15% on the chargeable income.
Mauritius has adopted the Partial Exemption Regime whether there are particular income streams which will qualify for the 80% partial tax exemption, thus, reducing the tax rate to 3%. The said income streams are as follows:

a. Foreign dividend derived by the company.
b. Interest derived by a company other than bank.
c. Income derived from ship/aircraft leasing.
d. Income attributable to Permanent Establishment.
e. Income from Collective Investment Scheme (CIS) / Closed-End Fund (CEF) / CIS Manager / CIS Administrator / Adviser / Asset Manager approved by the Financial Services Commission (FSC).
f. Reinsurance / Reinsurance brokering activities.
g. Leasing & provision of international fibre capacity.
h. Sale, financing, arrangement, asset management of aircraft and its spare parts and aviation advisory services related thereto.

A GBC should ensure that its audited financial statements are prepared filed to the authorities within 6 months of its year end. Failure to submit the accounts within the prescribed deadline will entail an administrative penalty of USD 10 per business day until the accounts are eventually filed with the Financial Services Commission (FSC).

The AC is treated as non-resident for tax purposes in Mauritius and as such is not liable to tax .
The requirements to be eligible to apply for a licence of Authorised Company are as follows:

1. The Company is controlled by a majority of shareholders with beneficial interest who are not citizens of Mauritius;
2. The activities of the Company are being conducted principally outside Mauritius; and
3. The Company has its place of effective management outside Mauritius.

Accounting, tax and audit requirements for AC
AC must file a return of income with the tax authorities of Mauritius.Aditionally it must file a financial summary with the authorities (a short form financial statements in a prescribed format) to the authorities within 6 months of its accounting year end. Failure to submit the accounts within the prescribed deadline will entail an administrative penalty of USD 10 per business day until the accounts are eventually filed with the FSC.

A Trust is an “agreement” between the settlor and the trustee in which the settlor transfers the legal ownership, dominion and control of the assets to trustees for the benefit of the beneficiaries pursuant to a Trust Deed.

An arrangement for the holding and administration of property under which property or legal rights are vested by the owner of the property (the Settlor) in a person or persons (the Trustees). The Trustees then hold the property for or on behalf of other persons (the Beneficiaries).

Key aspect of Trusts as does estate planning. Continuity of ownership is also secured through a holding by a Trust.

Tax Planning – A properly established Trust may produce substantial savings in income tax, capital gains tax and inheritance tax/estate duty;

• Avoiding Probate – Estate Planning – Protection against creditors
• Tax implications

Mauritius Trusts is now subject to an income tax at the rate of 15% on its chargeable income. However, a trust which is non-resident will still be exempted from taxation.

A Trust is deemed to be non-resident if its central management and control is outside Mauritius that is;

1. the trust is administered in Mauritius and a majority of the trustees are not resident in Mauritius;
2. the settlor of the Trust was not resident in Mauritius at the time the instrument creating the trust was executed or at such time as the settlor adds new property to the trust; and
3. a majority of the beneficiaries or the class of beneficiaries appointed under the terms of the trust are not resident in Mauritius

• A non-resident trust shall be liable to taxes only if it has chargeable income attributed to Mauritian source income.
• A non-resident trust shall however be required to submit a return of income to the Mauritius Revenue Authority (MRA). The return of income shall specify all income derived by it during the preceding income year and such other particulars as may be required by the MRA.

South African (“SA”) tax perspective, is the place of effective management (“PoEM”) of that trust. South Africa charges tax on a residency basis, and for a juristic person such as a trust, it would qualify as a SA tax resident where it has its PoEM in South Africa. Whilst the effective management of an offshore trust should always be considered based on its own facts and circumstances, it is pertinent to ensure that the SA settlor does not control the actions and affairs of the offshore trust to the exclusion of the offshore trustees. The offshore trustees must be able to evidence that management and control of the trust occurs in Mauritius.

A domestic company is governed by the Companies Act 2001, the Business Registration Act 2002, and is involved mainly in onshore business activities with Mauritius residents such as trading, consultancy services, investment holding, amongst others. Its main Features are :

• 100% foreign ownership
• No minimum stated capital requirement
• Minimum of one (1) resident director required
• Minimum of one (1) shareholder required who can be a non-resident of Mauritius
• File an annual return with the Registrar of Companies, audited accounts required if turnover is above MUR 50 Million
• File corporate tax return at rate of 15%

Assistance with Business Registration Mauritius

This includes :

• Advising on the relevant structures
• Provision of the substance requirements concerning local directors, registered offices and the various AMLR requirements, business permits / trading licences / opening of bank accounts
• assistance with finding you offices, staff, accommodation to live, occupational and residence permits
• assistance in the setting up office equipment/ phone lines/ internet/ electricity or any other necessities needed to initiate your business. While setting up your business, we will make sure that your relocation process is smooth and seamless and provide you with everything you need.

A Protected Cell Company (‘PCC’) is a single legal structure that can segregate its assets between different cells within the PCC. A PCC may carry only such activities as stated under the PCC Act and they are as follows:

• Asset holding
• Collective Investment Schemes (CIS)/Funds
• Insurance business
• Structured finance businesses

Key benefits:

• Each cell has its own responsibilities in terms of its assets and liabilities and they are separate from the other cells within the PCC.
• Creditors of a particular cell have recourse only to that cell.

We offer the following services:

• Investment Adviser Licence
• Investment Adviser (Unrestricted) Licence 
• Insurance Brokerage Licence
• Insurance Banking Licence
• Payment Intermediary Services Licence 
• Global Headquarters Administration Licence 
• Investment Dealer Licence
• Global Treasury Activities Licence
• Robotic and Artificial Intelligence Enabled Advisory Services Licence