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Corporate Structures

The Flagship Mauritian International Vehicle

The Global Business Company is Mauritius's premier corporate structure for cross-border investment, trading, and holding operations, combining treaty access, regulatory credibility, and a proven track record as a gateway to Africa, Asia, and beyond.

Overview

What is a Global Business Company?

A GBC is a tax-resident company incorporated under the Companies Act 2001 and licensed by the Financial Services Commission. Access to relief under Mauritius's 45+ DTAAs is available to a GBC that holds a valid Tax Residence Certificate and satisfies Mauritius management-and-control / substance requirements; 44 of Mauritius's treaties are Covered Tax Agreements under the OECD Multilateral Instrument, so treaty relief also remains subject to the Principal Purpose Test anti-abuse rule.

Typical applications include holding vehicles for African and Asian investments, regional headquarters for multinational groups, trade finance and treasury companies, IP holding and royalty structures, private equity fund holding entities, and joint venture vehicles.

A GBC pays corporate tax at 15%, with an 80% partial exemption available on certain categories of qualifying foreign-source income — including foreign dividends, foreign-source interest, and income from FSC-licensed fund/investment-management activity, ship and aircraft leasing, and a number of other specified categories — each subject to economic-substance conditions. Mauritius does not levy capital gains tax at all, on shares or otherwise. Royalty income does not fall within the partial-exemption categories and is generally subject to standard corporate tax, with treaty relief assessed separately where applicable. For any international group seeking a credible, treaty-backed Mauritian presence, the GBC remains a strong choice.

45+
Double Taxation Agreements
Mauritius's treaty network spans Africa, Asia, Europe, and beyond, providing unrivalled access for cross-border investment flows.
15%
Corporate Tax Rate
With partial exemptions applicable to qualifying income streams, the effective rate for many GBCs is considerably lower.
8–12
Weeks, Typical Establishment
From initial engagement to fully operational entity, including FSC licensing and banking establishment.

What We Provide

Key Features of the GBC

Treaty Network Access
Access to relief under Mauritius's 45+ DTAAs for a GBC holding a valid Tax Residence Certificate and satisfying management-and-control / substance requirements; 44 of Mauritius's treaties are Covered Tax Agreements under the OECD Multilateral Instrument, so relief remains subject to the Principal Purpose Test anti-abuse rule.
FSC-Licensed & Regulated
A GBC is issued a Global Business Licence by the Financial Services Commission, providing a regulated, internationally recognised corporate vehicle with demonstrable regulatory oversight.
COMESA & SADC Gateway
Mauritius's membership of COMESA and SADC, combined with its strategic location and bilateral investment treaties, makes the GBC an ideal vehicle for African investment platforms.
Full Foreign Ownership
A GBC may be 100% foreign-owned with no requirement for local participation, providing complete flexibility for international groups structuring through Mauritius.
Corporate Tax at 15%
Subject to Mauritius corporate income tax at a flat rate of 15%, with a partial exemption regime reducing the effective rate on qualifying passive income streams to as low as 3%.
Banking Facilitation
Aurevya's established relationships with Mauritian and international banks significantly improve the prospects of successful multi-currency account establishment for the GBC.

Process

How It Works

01
Feasibility & Structure Design
We assess the client's objectives, existing structure, and target jurisdictions to determine whether a GBC is the optimal vehicle and how it should be positioned within the wider group.
02
Company Incorporation
The company is incorporated at the Registrar of Companies under the Companies Act 2001. Name reservation, Articles of Association, and all statutory documentation are prepared by our team.
03
FSC Licence Application
A comprehensive licence application is submitted to the Financial Services Commission, including business plan, KYC documentation for all relevant parties, and governance framework documentation.
04
Registered Office & Management
The GBC is established at Aurevya's registered office, with qualified resident directors appointed to satisfy FSC substance requirements and provide active governance from day one.
05
Banking Establishment
We introduce the entity to our preferred banking partners, prepare the full application package, and liaise directly with compliance departments to facilitate account opening.
06
Ongoing Compliance
Annual compliance reviews, FSC renewals, MRA tax filings, audited financial statements, and AML/CFT programme maintenance are managed by Aurevya's specialist teams throughout the life of the entity.

Practical Considerations

Requirements & Timeline

Regulatory Requirements

  • Minimum 2 directors, at least 2 of whom must be resident in Mauritius
  • Qualified Company Secretary (FSC-approved)
  • Registered office maintained in Mauritius
  • Annual audited accounts prepared under IFRS
  • Corporate tax returns filed with the Mauritius Revenue Authority
  • Demonstrable substance in Mauritius including active management and control
  • AML/CFT compliance programme in place from incorporation
  • Annual FATCA/CRS reporting obligations where applicable

Indicative Timeline

  • Company Incorporation: 5–7 business days from submission of complete documentation to the Registrar of Companies
  • FSC Licence: 4–6 weeks from submission of a complete application, subject to FSC processing timelines and any queries
  • Banking: 4–10 weeks depending on the institution selected, the nature of the business, and the completeness of the KYC package
  • Full Operational Status: Typically 8–12 weeks from initial engagement to a fully licensed, banked entity

Common Questions

Frequently Asked Questions

A GBC is a tax-resident entity in Mauritius and has access to the country's full network of Double Taxation Avoidance Agreements. It requires an FSC licence and must meet substance requirements. An Authorised Company (AC), by contrast, is not considered a Mauritius tax resident; it is a non-resident vehicle that cannot benefit from DTAAs and carries a lighter regulatory and cost burden. The appropriate structure depends entirely on whether treaty access is commercially important to the client's objectives.
A GBC is subject to Mauritius corporate income tax at 15% on chargeable income. However, an 80% partial exemption is available on certain categories of qualifying income, including dividends and interest (subject to substance conditions); royalties are taxed at the standard 15% rate and capital gains on shares are not taxed at all under a separate, unconditional rule, rather than falling within the 80% exemption regime. The GBC files annual corporate tax returns with the Mauritius Revenue Authority and may also have FATCA and CRS reporting obligations depending on its activities and shareholder base.
Yes. A GBC may hold bank accounts both in Mauritius and internationally. In practice, the primary operating account will typically be held with a Mauritian bank, which may also provide multi-currency facilities and international payment capabilities. For certain business models, accounts may additionally be established at reputable international institutions in other jurisdictions, subject to each bank's own acceptance criteria and due diligence requirements.
The FSC requires that a GBC demonstrate genuine substance in Mauritius. This includes: having at least two resident directors who actively participate in board decisions; holding board meetings in Mauritius with appropriate documentation; maintaining accounting records and corporate books in Mauritius; and ensuring that core income-generating activities and key management decisions occur within the jurisdiction. Aurevya's board services and governance practice ensures that all substance obligations are met systematically and documented appropriately.
From the point of engagement, the typical timeline to a fully licensed and banked GBC is 8–12 weeks. Company incorporation takes 5–7 business days; the FSC licence application typically requires 4–6 weeks for processing; and banking establishment adds a further 4–10 weeks depending on the institution and the completeness of the client's KYC documentation. Aurevya's streamlined process and established relationships compress these timelines wherever possible.

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