Mauritius Treaty Company Formation

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Treaty Jurisdictions

Double Taxation Agreement Networks

Mauritius Treaty Company Formation and Requirements

Mauritius has an extensive treaty network covering over 46 countries with particular depth in Africa, India, and Asia. The Global Business Company (GBC) is the primary structure used for treaty access and is commonly used to hold investments into India (under the revised India-Mauritius treaty), Sub-Saharan Africa, and other emerging markets where Mauritius has preferential treaty rates.

Mauritius is governed by the Financial Services Act and is regulated by the Financial Services Commission (FSC). The GBC structure requires genuine substance in Mauritius including local management, resident directors, and core income generating activities performed in the jurisdiction.

Tax Rate

The standard corporate tax rate in Mauritius is 15%. However, a GBC can benefit from a foreign tax credit of up to 80% of Mauritius tax on foreign source income, reducing the effective tax rate to as low as 3%.

African Treaty Access

Mauritius treaties with African countries including Kenya, Rwanda, Uganda, Zimbabwe, Mozambique, and Madagascar provide significantly reduced withholding tax rates, making Mauritius the leading holding platform for Africa investments.

GBC Substance Requirements

A GBC must maintain at least two Mauritius resident directors, hold board meetings in Mauritius, maintain its principal bank account in Mauritius, maintain its accounting records in Mauritius, and meet the FSC's enhanced substance test.

Regulatory Oversight

The FSC regulates all GBCs. Annual renewal of the GBC licence, annual financial statements, and compliance with the AML/CFT framework are mandatory. Neptune Fiduciaries Group manages all FSC compliance obligations on behalf of clients.

Get in Touch

Contact Neptune Fiduciaries Group via info@neptunecorporate.com or visit our Contact Us page.

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