Mauritius GBC

Mauritius GBC 1 Companies are resident in Mauritius and consequently subject to tax. However, they benefit from both tax credits and a longstop tax rate of 3%. Correctly structured and managed Mauritius GBC 1 companies may access Mauritius’ network of 37 tax treaties.
A company holding a Category 2 Global Business License on the other hand is often used for trading and investment. GBC II companies are not resident for tax purposes and do not have access to Mauritius’ tax treaty network. Beneficial ownership is not disclosed to the authorities.
Category 1 Global Business Licence (GBC1)
A GBC1 is a corporation which may undertake any of the following activities as listed below which is carried on from within Mauritius with persons all of whom are resident outside Mauritius and which is conducted in foreign currency:

• Aircraft financing and leasing
• Assets management
• Consultancy services
• Employment services
• Information and communication technologies
• Insurance
• Licensing and franchising
• Logistics and or marketing
• Operational headquarters
• Pension funds
• Shipping and Shipping Management
• Trading
• Any other activity as may be approved by the
• Commission

It is qualified to take protection of the tax treaties to which Mauritius is a party if it comes within the definition of a resident under the taxation laws.
A GBC 1 is required to file with the Financial Services Commission within six months after the close of its financial year annual audited financial statements prepared in accordance with the International Accounting Standards or internationally recognised accounting standards.
The GBC 1 may be set up by direct incorporation or by registration of a branch of a foreign company, or by way of continuation where this is allowed by the law in the country of origin. A branch of a foreign company may have access to Mauritius’ tax treaties provided that the local tax authorities are satisfied that effective control and management of the foreign company is in Mauritius. The facility of continuing a foreign company registered in a foreign jurisdiction as a GBC 1, and so permitting existing holdings of the foreign company in a country with which Mauritius has a double taxation treaty to benefit from relief under that treaty, has proved attractive to a number of major investors. A GBC 1 may be unlimited or limited by shares or by guarantee. A GBC 1 may be registered as a Limited Life Company or a Protected Cell Company.
Category 2 Global Business Licence (GBC2)
A GBC2 can carry out most business activities but only with non-residents and in currencies other than the Mauritian rupee. However, it is not tax resident in Mauritius and therefore cannot benefit from the DTA network. It is completely exempt from paying taxes in Mauritius.
A GBC2 enjoys a flexible legal regime. Companies that are engaged in invoicing, marketing and international trading activities will often use a GBC2 structure.
A GBC2 can conduct any business activities other than the following: banking, financial services, carrying out the business of holding or managing or otherwise dealing with a collective investment fund or scheme as a professional functionary, providing of registered office facilities, nominee services, directorship services, secretarial services or other services for corporations, providing trusteeship services by way of business.

Table of Comparison	GBC1	GBC2
Corporate Taxation	Effective rate of 3%	Nil
Double Taxation Treaty Access	Yes	No
Minimum Paid Up Share Capital	No Minimum	No Minimum
Currency	Any currency except Mauritian Rupee	Any currency except Mauritian Rupee
Carry out Financial Services Activities	Yes	No
Raise Funds from Public	Yes	No
Publicly accessible records	No	No
Location of Meetings	Mauritius	Anywhere
Bank Account in Mauritius	Yes	Yes
Physical Office in Mauritius/Expatriate and Local Staff	Yes	No
Directors
– Minimum Number	One	One
– Requirement for Local Resident Director	Yes, but 2 required for tax treaty access	No
– Corporate Directors	No	Yes
Shareholders
– Minimum Number	One	One
– Corporate Shareholders	Yes	Yes
– Nominee Shareholders	Yes	Yes
Company Secretary
– Required	Yes	Yes, in case of one person company
– Local or qualified	Both	No
Accounts
– Requirement to prepare	Yes	Yes
– Audit requirements	Yes	No
– Requirement to file accounts	Yes	Yes
– Publicly accessible accounts	No	No
Disclosure Requirement
Disclosure of Beneficial Owners/shareholder/directors to the authorities	Yes	Yes