Two of the most commonly used corporate structures in Mauritius are the Global Business Company (GBC) and the Authorised Company (AC). On the surface, both are Mauritius-incorporated entities available to non-residents. In practice, they serve fundamentally different purposes and carry distinct tax, substance, and operational implications. Choosing incorrectly can expose a structure to tax leakage, treaty disqualification, or regulatory non-compliance, all of which are expensive to unwind.
The Global Business Company (GBC)
The GBC is Mauritius's flagship international business vehicle. Licensed by the Financial Services Commission, it qualifies as a tax resident of Mauritius and is eligible for the benefits of Mauritius's double taxation agreement network. The headline corporate income tax rate is 15%, with an 80% partial exemption on qualifying foreign-source income, reducing the effective rate on foreign income to as low as 3%.
The GBC requires genuine substance in Mauritius: at minimum two resident directors, a licensed management company as company secretary and registered agent, a local bank account, board meetings held and minuted in Mauritius, and adequate staffing to demonstrate that management and control genuinely reside in the jurisdiction. This substance requirement is the legal and factual predicate for treaty eligibility: without it, treaty benefits can and will be denied by source-country tax authorities.
The GBC is the appropriate vehicle when treaty benefits are needed, when the entity holds investments in treaty-partner jurisdictions, when it earns cross-border royalties, interest, or dividends, or when it is presented to institutional counterparties who require evidence of a regulated, credible structure.
The Authorised Company (AC)
The Authorised Company is incorporated under the Companies Act 2001 and authorised by the Registrar of Companies. It is specifically designed for entities whose business is conducted exclusively outside Mauritius. Critically, the AC is not a tax resident of Mauritius for treaty purposes and therefore cannot access Mauritius's DTA network. It pays no Mauritius corporate income tax, but it also derives none of the treaty protection that makes the GBC valuable.
The AC has lower ongoing compliance costs: it does not require FSC licensing, its substance requirements are lighter, and its annual fees are lower. These cost advantages make it attractive for holding structures where treaty access is genuinely unnecessary: for example, a vehicle holding only non-treaty-partner assets, or a personal holding company for a family with no cross-border tax exposure requiring treaty protection.
A common structural error is using the AC as a lower-cost substitute for a GBC in situations where treaty benefits are actually needed. An AC used in treaty-relevant transactions will not be protected from source-country withholding taxes, and tax authorities will correctly deny treaty benefits to an entity that cannot establish Mauritius tax residence.
Key Decision Criteria
The correct choice turns on four questions. First, does the entity need treaty access? If yes, the GBC is required. Second, will the entity earn income from jurisdictions where treaty-reduced withholding taxes would materially affect net returns? Again, the GBC is required. Third, will the entity be presented to banks or investors who will scrutinise its structure? The GBC's FSC licence provides a level of institutional credibility the AC cannot match. Fourth, what is the ongoing cost tolerance? The GBC's costs are higher, but in most treaty-relevant situations, easily justified by the tax savings achieved.
Transitioning between structures is possible but involves regulatory steps, potential tax consequences in third jurisdictions, and banking disruption. Getting the structure right at inception is materially less expensive than correcting it after the fact.