Question 1

What is a GBC1 company and how does it differ from other structures?

Accepted Answer

A Global Business Company 1 (GBC1) is a tax-resident Mauritius company that can access the country's extensive tax treaty network. It pays 15% corporate tax but receives an 80% tax credit (called 'deemed foreign tax credit'), resulting in a 3% effective tax rate. Unlike offshore companies, GBC1s must demonstrate adequate substance in Mauritius and are subject to FSC regulation.

Question 2

How can I use Mauritius for investments into India?

Accepted Answer

The Mauritius-India tax treaty provides favorable capital gains tax treatment and reduced withholding taxes, making it popular for structuring Indian investments. However, you must meet substance requirements and demonstrate genuine business purpose. The treaty includes anti-abuse provisions and limitation on benefits clauses that require adequate substance and commercial rationale.

Question 3

What are the substance requirements for a GBC1 company?

Accepted Answer

You need: (1) At least 2 directors with one Mauritian resident, (2) Physical office in Mauritius with adequate staff, (3) Board meetings held in Mauritius, (4) Core activities conducted from Mauritius, (5) Adequate operating expenses, (6) Bank account with Mauritian bank, (7) Accounting records in Mauritius. The specific requirements vary based on your business activities.

Question 4

How long does it take to set up a Mauritius company?

Accepted Answer

Complete setup typically takes 6-8 weeks including: company registration (5-7 days), FSC Global Business License (2-3 weeks), bank account opening (3-4 weeks), and tax registration (2-3 weeks). Timeline can vary depending on complexity, bank requirements, and completeness of documentation.

Question 5

Can non-residents be directors and shareholders?

Accepted Answer

Yes, non-residents can be shareholders with no restrictions. For directors, you need at least 2 directors with at least one being a Mauritian resident. The Mauritian resident director requirement is crucial for substance compliance and accessing tax treaty benefits. We can provide qualified resident directors if needed.

Question 6

What are the ongoing costs of maintaining a Mauritius company?

Accepted Answer

Annual costs include: (1) FSC license fee ($1,100-$2,200 based on turnover), (2) Registered office and company secretary ($1,500-$2,500), (3) Audit fees ($1,500-$3,000), (4) Accounting and tax compliance ($1,000-$2,000), (5) Resident director fees if required ($2,000-$4,000). Total annual costs typically range from $7,000-$14,000.

Question 7

What is the effective tax rate for a Mauritius GBC1 company?

Accepted Answer

Mauritius GBC1 companies benefit from a 3% effective tax rate. While the statutory corporate tax rate is 15%, companies receive an 80% deemed foreign tax credit, reducing the effective rate to 3%. Additionally, there is no capital gains tax, no withholding tax on dividends paid to non-residents, and access to foreign tax credits under double taxation agreements.

Question 8

Which countries have tax treaties with Mauritius?

Accepted Answer

Mauritius has 43 Double Taxation Avoidance Agreements (DTAAs) including major economies like India, China, South Africa, Singapore, Thailand, Bangladesh, UK, France, Germany, Luxembourg, Belgium, and UAE. These treaties provide reduced withholding tax rates and favorable capital gains treatment, making Mauritius ideal for structuring investments into Africa and Asia.

Feature	Global Business Company (GBC1)	Domestic Company
Best Use For	International trading, holding companies, fund management	Local operations, domestic business
Tax Rate	3% effective (15% with 80% tax credit)	15% standard corporate tax
Substance Requirements	Must meet substance requirements (office, employees)	Full local presence required
Director Requirements	Minimum 2 directors (at least 1 Mauritian resident)	Minimum 2 directors (Mauritian residents)
Shareholder Requirements	Minimum 1 shareholder (any nationality)	Minimum 1 shareholder
Minimum Capital	No minimum requirement	MUR 100,000 (≈$2,500)
Audit Requirements	Annual audit required	Annual audit required
Annual Filing	Annual return and audited accounts	Annual return and audited accounts

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