Mauritius Global Business Guide 2026

Overview — Global Business in Mauritius

Mauritius has developed a world-class international business centre (IBC) regime, regulated by the Financial Services Commission (FSC). Companies holding a Global Business Licence Category 1 (GBL1) can conduct business outside Mauritius while being tax resident in Mauritius and accessing the country's extensive DTT network. The regime is compliant with OECD standards, including economic substance requirements, and is regularly reviewed by the European Union and OECD for tax transparency.

GBL1 Licence — Effective 3% Tax Rate

The GBL1 licence is the primary vehicle for international business in Mauritius. Key features:

• Tax rate: 15% CIT, but an 80% deemed Foreign Tax Credit (FDC) applies to foreign-source income, resulting in an effective rate of approximately 3%
• Foreign-source income: Includes dividends, interest, royalties, capital gains from foreign investments, and income from foreign trading activities
• No CGT: Capital gains on disposal of foreign investments are not taxed
• No WHT on dividends: Dividends paid by a GBL1 company to non-resident shareholders are not subject to Mauritian withholding tax
• Treaty access: GBL1 companies can access Mauritius's DTT network, subject to Limitation of Benefits (LOB) provisions

The FDC is automatic and does not require the company to have actually paid foreign tax — it is a deemed credit that reduces the effective rate regardless of the actual tax paid in the source jurisdiction.

Economic Substance Requirements

In compliance with OECD BEPS standards and EU requirements, GBL1 companies must demonstrate economic substance in Mauritius:

• Physical presence: A physical office in Mauritius (owned or leased) appropriate for the activity
• Qualified employees: Sufficient number of qualified employees physically present in Mauritius (typically at least 2–3 full-time staff)
• Management and control: Board meetings held in Mauritius, strategic decisions made locally, minutes maintained in Mauritius
• Operating expenditure: Adequate operating expenditure in Mauritius relative to the income generated
• Core income-generating activities (CIGA): Key business activities must be performed in Mauritius

GBL1 companies must file an annual substance declaration (Form 8) with the FSC, along with audited financial statements. Failure to demonstrate substance may result in the loss of the GBL1 status and the company being treated as a domestic company (taxed at 15% without FDC).

Holding Company Structures

Mauritius is a premier jurisdiction for holding companies due to the following advantages:

• Participation exemption: Dividends received by a Mauritian holding company from its subsidiaries are exempt from CIT
• 0% CGT: Gains on the sale of shares in subsidiaries are not taxable
• 0% WHT on outbound dividends: Profits can be repatriated to the parent company without withholding tax
• Treaty network: Reduced WHT rates on dividends, interest, and royalties from treaty partners (e.g., 5% dividends to India, 0% dividends to UK, France, South Africa)
• No CFC rules: Passive income of the holding company is not attributed to shareholders
• No thin capitalisation rules: Flexible debt/equity structuring (subject to transfer pricing arm's length principle)

FSC Regulatory Framework

The Financial Services Commission (FSC) regulates GBL1 companies, alongside other financial services. Key regulatory requirements:

• Licensing: All GBL1 companies must obtain a licence from the FSC
• Corporate governance: At least two directors (one resident in Mauritius), board meetings held regularly
• Company secretary: A company secretary resident in Mauritius (usually provided by a management company)
• Registered office: A registered office in Mauritius (provided by a management company)
• Audit: Annual audited financial statements by a licensed auditor in Mauritius
• Annual return: Annual return (Form 8) filed with the FSC including substance declaration

Comparison: GBL1 vs Domestic Company

• GBL1 company: 15% CIT with 80% FDC → effective 3% on foreign-source income. Subject to FSC regulation and substance requirements. Can access DTT network. Used for international business, holding, and investment
• Domestic company: 15% CIT on worldwide income. No FDC benefit. Not subject to FSC regulation. Cannot access DTT network for foreign income. Used for local Mauritian business operations

FAQs

What is the difference between GBL1 and GBL2 (now Authorised Company)?

The GBL2 category has been abolished and replaced by the Authorised Company (AC) regime. Authorised Companies are not tax resident in Mauritius (they are treated as foreign companies) and are not entitled to treaty benefits. GBL1 companies are fully tax resident and can access DTTs.

Can a GBL1 company invest in Mauritius?

GBL1 companies are primarily intended for business outside Mauritius. If a GBL1 company derives income from Mauritian sources, that income is treated as domestic income and taxed at 15% without the FDC benefit. The company should consider separate domestic incorporation for local activities.

What are the costs of setting up and maintaining a GBL1 company?

Typical costs include: FSC licence fee (approximately USD 1,500–3,000 per year), management company fees (USD 5,000–15,000 per year for registered office, secretary, and compliance), audit fees (USD 3,000–8,000 per year), and tax advisory fees. Total annual maintenance costs typically range from USD 10,000 to USD 25,000 depending on complexity.

Disclaimer

This guide provides general information about the Mauritian Global Business regime for the 2026 tax year. Tax laws, regulations, and substance requirements may change. Always consult with a qualified Mauritian legal and tax advisor or the FSC for advice specific to your international business structure. InvestmentKit does not provide tax advice.