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Mauritius introduced the Protected Cell Company (PCC) under the Protected Cell Companies Act 1999, making it one of the earliest jurisdictions to adopt PCC legislation. The Mauritius PCC is regulated by the Financial Services Commission (FSC) and is widely used for investment funds, captive insurance, and structured finance, particularly for business flows into Africa and Asia where Mauritius has a broad treaty network.
Africa Investment Platform
A Mauritius PCC used for African investment funds benefits from Mauritius's extensive network of double taxation agreements with African countries, providing reduced withholding tax rates on dividends and interest from Sub-Saharan Africa.
FSC Regulated Framework
PCCs in Mauritius are licensed and supervised by the FSC. A Collective Investment Scheme (CIS) licence is required for investment PCCs, while an insurance licence is required for insurance PCCs. The FSC is an internationally recognised and cooperative regulator.
Favourable Tax Regime
Mauritius PCCs benefit from the 15% corporate tax rate with an 80% foreign tax credit on foreign source income, reducing the effective tax rate to 3% for income derived from treaty countries. Capital gains from disposal of securities are exempt from tax.
Cell Separation and Liability Containment
The Protected Cell Companies Act 1999 provides that assets of each cell are legally separated and unavailable to satisfy the liabilities of other cells or the general liabilities of the core company, providing robust statutory ring-fencing.
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