Global Business Company (GBC): A complete guide to investing in Mauritius

Mauritius has become a strategic hub for international investors, offering legal stability, an attractive tax regime, and access to an extensive network of double taxation treaties. To structure global operations effectively, the Global Business Company (GBC) stands out as an efficient, flexible, and internationally recognised business vehicle.

What is a Global Business Company (GBC)?

A Global Business Company (GBC) is a Mauritian-registered entity specifically designed to conduct international trade and investment activities. It enables investors to structure their global operations while benefiting from substantial tax advantages.

Since 1 January 2019, companies previously categorised as GBC1 have been reclassified as Global Business Licence (GBL) entities. This reform replaced the former Foreign Tax Credit (FTC) regime with a partial exemption system, granting up to 80% tax exemption on selected types of foreign income such as dividends, interest, profits from foreign permanent establishments, and income from specialised activities like reinsurance or international leasing.

To qualify for this exemption, companies must meet economic substance requirements in Mauritius, meaning that core activities, management, and control must actually be carried out on the island. This includes having resident directors, a local bank account, and financial statements prepared and maintained in Mauritius.

In short, a GBC combines tax efficiency, operational flexibility, and international compliance, making it an ideal vehicle for investors and entrepreneurs managing cross-border operations from Mauritius.

Which income qualifies for tax exemption in Mauritius?

GBCs may benefit from a partial exemption on:

• Foreign dividends not deductible in the source country;
• Interest income and profits attributable to a foreign permanent establishment;
• Income from investment funds, including CIS and closed-end funds managed by Financial Services Commission (FSC)-licensed entities;
• Income derived from reinsurance, ship or aircraft leasing, and related services;
• Income generated by companies licensed in artificial intelligence or payment services.

Investment and closed-end funds may also qualify for a 95% exemption on interest income. GBCs benefiting from the 80% exemption, however, are not eligible to claim a tax credit on this foreign income.

The Tax Residence Certificate (TRC) and Double Tax Treaties

To benefit from tax advantages and Double Tax Treaties (DTTs), a GBC must hold tax residency status in Mauritius and obtain a Tax Residence Certificate (TRC) from the Mauritius Revenue Authority (MRA). The TRC is typically issued within seven days of submitting all required documentation.

Mauritius has signed 44 double taxation treaties, providing international investors with protection against double taxation and enabling efficient tax planning for their global operations.

Management and substance requirements in Mauritius

A GBC must be managed and controlled from Mauritius to maintain tax residency and qualify for exemptions. The main criteria include:

• At least two resident directors capable of making independent decisions;
• At least two resident directors capable of making independent decisions;
• Accounting records and statutory documents kept locally;
• Financial statements prepared and audited in Mauritius;
• Board meetings held in Mauritius with the participation of at least two resident directors.

Certain functions may be outsourced to licensed service providers, provided that effective management remains in Mauritius and economic substance is not duplicated.

Tax and operational benefits of a GBC

GBCs can benefit from an 80% exemption on selected foreign income streams, maximising profitability while remaining fully compliant with local tax regulations.

Exemption on foreign income

Eligible income includes interest, dividends, profits from foreign permanent establishments, reinsurance, and leasing of international assets.

Access to Double Taxation Treaties

With a Tax Residence Certificate (TRC), a GBC can benefit from the Double Tax Treaties (DTTs) signed by Mauritius with 44 countries, reducing or eliminating double taxation and facilitating the structuring of international operations.

Operational flexibility

The GBC structure allows for the management of a wide range of activities:

• Fund management and international investments;
• Ship and aircraft leasing;
• Payment services and international financial operations;
• Activities related to artificial intelligence and technology.

This flexibility makes it an ideal choice for entrepreneurs seeking to combine favourable taxation with global business opportunities.

International recognition

GBCs are recognised for their compliance with international governance and reporting standards, strengthening their credibility with partners and financial institutions worldwide.

4 steps to set up a GBC in Mauritius

Establishing a Global Business Company in Mauritius may appear complex, but with the right guidance, the process is clear and straightforward. Here’s a typical workflow:

1. Prepare and certify the necessary documents, including the constitution and identification of shareholders and directors;
2. Submit the application through a licensed Management Company to ensure full compliance and communication with the FSC;
3. Obtain the TRC to access tax benefits and double taxation treaties;
4. Finalise official registration and maintain ongoing compliance — including accounting, auditing, and board meetings.

Why establish a GBC in Mauritius?

Mauritius provides a secure and business-friendly environment for international investors, offering:

• Tax optimisation through exemptions and DTTs;
• Operational flexibility to structure and expand international activities;
• Regulatory stability under the supervision of the FSC and MRA;
• Global credibility through adherence to international governance standards;
• Access to an extensive DTT network, protecting and facilitating cross-border investments.

Conclusion

Setting up a Global Business Company (GBC) in Mauritius requires expertise, efficiency, and precision to secure your investments and ensure full tax compliance.

For a seamless and reliable incorporation process, partner with C&S Secretarial Services. We manage every step, from fast company formation to administrative and tax management, as well as coordination with local authorities, so you can focus on growing your business.

Contact us today to establish your GBC in Mauritius.

Source:

Global Business Licence (GBL) companies – taxsummaries.pwc.com