The President has assented to the Finance Act 2026 (Act No. 14 of 2026), giving legal effect to the measures announced in the 2026–27 Budget. It arrived together with a companion statute, the Economic and Financial Measures (Miscellaneous Provisions) Act 2026 (Act No. 13), which carries a further set of financial-services amendments. Between them, the two Acts touch almost every structure Aurevya administers: global business companies, trusts and foundations, family offices, funds and their managers, and the individuals behind them.

Budget commentary in June told you what was proposed. Now that the text is law, the more useful question is what it means for your structure, and what has a deadline attached. This note takes each client type in turn.

If You Own a Global Business Company

The headline for GBC owners is not in the Act at all, but arrived alongside it: the FSC's licensing fees were realigned from 1 July 2026, taking the annual GBC fee from USD 1,950 to USD 2,600 and the Authorised Company fee from USD 350 to USD 1,400, with the payment deadline for this year's renewals extended to 30 September 2026, now weeks away. If your renewal is unpaid, that date matters more than anything else in this article.

Within the Act, the changes for GBCs are mostly at the edges of the regime. The Tax Residence Certificate, the document a GBC presents to a foreign tax authority to claim treaty benefits, now costs more, effective 1 July 2026: USD 2,000 rather than USD 1,000 for a collective investment scheme, USD 500 rather than USD 200 for other companies, and Rs 2,000 rather than Rs 1,000 for individuals. The captive-insurance tax holiday is extended by five years for licensees in place before 19 June 2026. And a housekeeping obligation with a hard deadline: registers of beneficial owners must record each beneficial owner's date of birth by 30 June 2027. It sounds administrative, and it is, but incomplete registers are the kind of finding the FSC's revised enforcement approach is increasingly built to catch.

If You Are a Settlor of a Trust or Founder of a Foundation

Here the Act makes the most conceptually significant change: it rewrites who counts as a global business entity. From 1 July 2027, a foundation qualifies only where its founder, and its beneficiaries, are non-residents or themselves hold a Global Business Licence; trusts face the equivalent test for settlors and beneficiaries, with a carve-out for purpose trusts whose purpose is carried out outside Mauritius. Trustees of unit trust schemes who are non-resident or GBL-licensed are brought into the definition for the first time.

The practical effect: a trust or foundation with Mauritian-resident individuals in the chain will generally fall outside the global business regime, and with it, the partial exemption that regime carries, from mid-2027. Structures set up years ago, when the residence of a second-generation beneficiary was nobody's concern, should be reviewed against the new test well before it bites. There is a full income year to restructure deliberately; there will not be if the review starts next June.

If You Run, or Are Building, a Family Office

The Act writes a Private Wealth Management Licence into the Financial Services Act, a modular licence conceived for wealth-management and family-office activity, alongside a new framework for pension income drawdown. The permitted activities will be fleshed out in FSC Rules that have not yet been issued, so the honest advice today is: this is the licence to watch, not yet the licence to file for. What can be said already is directional: Mauritius is building a bespoke home for private-wealth structures rather than asking family offices to borrow licences designed for third-party asset managers. For families weighing Mauritius against Dubai or Singapore for a family-office base, that is a meaningful signal, and Aurevya is tracking the Rules as they emerge.

If You Manage a Fund, or Are Structuring One

Three changes matter. First, the partial exemption regime is broadened: the core income-generating activities of an investment adviser or asset manager now include managing non-securities instruments, loan receivables, mortgage-backed exposures and invoice-financing portfolios. Private-credit managers, in other words, are brought squarely within the 80% exemption that securities managers have long enjoyed. Second, protected cell companies may now convert into variable capital companies with legal continuity, and a VCC may provide ancillary services to its sub-funds, removing the awkward choice between staying in a PCC and rebuilding from scratch in the newer vehicle. Third, under the Pillar Two rules, qualifying investment funds and real-estate investment vehicles are exempt from the domestic minimum top-up tax where they are the parent entity of a multinational group, with retrospective effect from 1 July 2025, and the mechanics have been softened, with returns due fifteen months from the fiscal year-end and the late-payment penalty halved from 5% to 2.5%. Managers of in-scope multinational groups should note that the MRA has already begun reminding groups of DMT return deadlines.

For virtual-asset businesses, one more line deserves attention: senior executives of VASPs must now meet Mauritius residency requirements, substance in the VAITOS sector is no longer only about where the servers are.

If You Are Moving Yourself, Not Just Your Structure

The individual side of the Act is generous at the bottom and firmer at the top. Personal income tax is rescaled from 1 July 2026, the first Rs 500,000 free of tax, then progressive bands rising to a new top rate of 35%, while the Fair Share Contribution is abolished. And in a change aimed directly at internationally mobile families, effective 1 July 2026, Golden Visa holders are now taxed on the same remittance basis as Premium Visa holders: foreign-source income is exempt unless remitted to Mauritius. For a family relocating with offshore portfolios, that alignment removes a quirk that made the choice of visa category a tax decision.

The Dates That Matter

  • 30 September 2026: Extended deadline for this year's FSC licence-fee payment at the new rates.
  • 30 June 2027: Beneficial-owner registers must include dates of birth.
  • 1 July 2027: The new global business definition takes effect for trusts and foundations.
  • As issued: The FSC Rules that will give the Private Wealth Management Licence its content.

The reviews these deadlines call for, of registers, of beneficiary residence, of whether a PCC should become a VCC, are exactly the work that is cheap done early and expensive done late.

How Aurevya Can Help

Aurevya structures and administers Mauritius Global Business Companies, Authorised Companies, trusts, foundations and family-office arrangements, and works with fund managers on FSC licensing. We can review an existing trust or foundation against the 2027 global business test, bring a beneficial-ownership register up to the new standard, assess whether the broadened partial exemption or a PCC-to-VCC conversion changes the economics of a fund structure, and advise families relocating under the occupation, Premium or Golden Visa routes.

Related reading: see how these changes apply to Mauritius's Investor Occupation Permit and to Single Family Office / Multi-Family Office structuring.

This article is a general commentary and does not constitute legal or tax advice. Several measures await implementing rules or MRA practice notes; please seek advice on your specific circumstances.