Global Business Corporation

The Global Business Corporation (GBC) is classified as an offshore corporation incorporated and resident in Mauritius for tax purposes. A GBC can take the form of a company, a limited partnership, a trust, a foundation, a protected cell company, a variable capital company and a société.

GBCs controlled by non-Mauritius residents may engage in commercial activities with Mauritius residents provided such activities represent a minority market share in comparison to its offshore market.

The benefits accessible to GBCs are as follows:

• 80% tax exemption on certain revenue streams.
• Access to the Mauritius network of Double Taxation Avoidance Agreements (DTAA).
• Confidentiality in terms of public access to information.
• Complete tax exemption for investment funds if structured wisely.
• Acquisition of properties in Mauritius.
• Access to work and residence permit.
• No foreign exchange control.
• No capital gains tax.
• No withholding tax on dividends, interest and royalties.
• No stamp duties.
• No inheritance tax.
• No thin capitalisation rules

A GBC wishing to benefit from the tax relief under the DTAA, requires a Tax Residence Certificate (TRC) issued by the Mauritius Revenue Authority and the TRC is granted only if the GBC demonstrates that management and control is in Mauritius. Accordingly, the GBC must:

• Appoint two directors who are resident in Mauritius.
• Chair its board meetings from within Mauritius.
• Ensure that its turnover goes through a bank account maintained by a bank in Mauritius.
• Appoint a Mauritian qualified company secretary.
• Appoint an auditor licensed by the FRC and recognized by MIPA.
• Carry out its core income generating activities in or from Mauritius by:
  • Employing either directly or indirectly a reasonable number of qualified persons to carry out its core activities.
  • Have a minimum level of expenditure commensurate with its level of activities.
• Be managed by a Management Company licensed by the FSC.