Insight

GBC vs Authorised Company vs Domestic Company in Mauritius: which structure is right for you?

Choosing the right company structure in Mauritius will influence how your business is governed, how it is taxed, which regulatory requirements apply and how effectively it can support your long-term objectives.

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Company formation and structuring in Mauritius

Structure first

Domestic, GBC or Authorised Company — match the vehicle to the business.

Modern commercial district in Mauritius
Context

Three structures. Different purposes.

Three options commonly considered are the Domestic Company, the Global Business Company (GBC) and the Authorised Company (AC). Although all three operate within Mauritius's corporate framework, they serve different purposes and are subject to distinct requirements.

A Domestic Company is generally used for businesses operating in Mauritius. A GBC is designed for global business activities through a Mauritius-resident structure. An AC is intended for business conducted principally outside Mauritius, with central management and control outside the jurisdiction.

The distinction is important. A company that is suitable for a local operating business may not be appropriate for an international investment platform. Equally, a structure designed for overseas activities may not deliver the intended outcome if its management arrangements or tax treatment are inconsistent with the business's actual operations.

This article provides general information and does not constitute legal or tax advice. Tax treatment and regulatory requirements depend on the circumstances of each case and the legislation in force at the relevant time.

At a glance

Which Mauritius company structure should you consider?

The starting point is your commercial objective, not the headline tax rate.

Domestic Company

Generally suited to businesses operating in Mauritius, including local trading, professional services and operating businesses.

Global Business Company

Suited to international business and investment where a Mauritius-resident structure, local governance and potential DTA access are relevant.

Authorised Company

May suit international trading, consultancy and asset-holding conducted principally outside Mauritius, where treaty access is not required.

These are general starting points rather than fixed rules. The appropriate structure depends on the activities proposed, ownership, income flows, management arrangements and the tax treatment in every relevant jurisdiction.

Domestic Company

Establishing and operating a business in Mauritius.

A Domestic Company is incorporated under the Companies Act 2001 and is commonly used for commercial activities carried out in Mauritius.

These may include retail and wholesale trading, consultancy, professional services, local operations and investment holding, subject to the requirements applicable to the particular activity. For a business with local customers, employees, suppliers or premises, a Domestic Company will often be the natural starting point.

The standard corporate income tax rate in Mauritius is generally 15%, subject to applicable exemptions, reliefs and special regimes. A partial exemption may be available on specified categories of income where the relevant statutory and substance conditions are met. A qualifying Domestic Company may also be eligible for benefits under a double taxation agreement, provided the relevant treaty conditions are satisfied.

Governance obligations typically include incorporation and registration, a registered office in Mauritius, the directors and company secretary required under applicable law, appropriate accounting and corporate records, and applicable tax, audit, reporting and statutory filing obligations.

Business operations and administration in Mauritius
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Global Business Company

A Mauritius-resident platform for international business.

A Global Business Company operates under Mauritius's global business framework, with a Global Business Licence issued by the Financial Services Commission (FSC).

It is commonly considered by international investors seeking to hold investments, conduct cross-border business or establish a structure through which activities involving several jurisdictions can be managed. A GBC is generally tax-resident in Mauritius and may apply to the Mauritius Revenue Authority for a Tax Residence Certificate to support a claim for treaty benefits.

An 80% partial exemption may be available on specified categories of income where the relevant statutory conditions are satisfied. Where that exemption applies to qualifying income otherwise taxable at 15%, the resulting effective corporate income tax rate on that income may be 3% — before considering any other applicable taxes or contributions. This is not an automatic tax rate for every GBC or every category of income.

Substance is not simply a registered address or a collection of formal appointments. Governance, personnel, expenditure and decision-making arrangements should be appropriate to the business and consistent with its claims about where and how it operates. Applications must be submitted through an appropriately licensed Management Company.

Authorised Company

An international structure managed from outside Mauritius.

An Authorised Company is incorporated under the Companies Act 2001 and authorised by the FSC to conduct business principally outside Mauritius, with central management and control outside the jurisdiction.

An AC must have a registered agent in Mauritius, performed by a licensed Management Company. It may be considered for certain international trading, consultancy and asset-holding activities, subject to ownership and regulatory requirements and restrictions on specified sectors.

An AC that satisfies the relevant conditions is generally treated as non-resident for Mauritius income tax purposes. It should not be assumed to be tax-free simply because it is incorporated in Mauritius — the jurisdiction where the company is managed and controlled may also tax it under its own domestic rules.

An AC is generally not eligible to claim benefits under Mauritius's DTAs in the same way as a qualifying Mauritius tax-resident company. Where treaty relief is important to an investment, this distinction may influence the choice of structure.

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Comparison

GBC vs Authorised Company vs Domestic Company.

An initial overview of the principal differences. Confirm tax rates, exemptions and obligations for the relevant accounting period.

Consideration Domestic Company Global Business Company (GBC) Authorised Company (AC)
Principal purpose Local or international business, depending on activities and requirements Global business through a Mauritius-resident structure Business conducted principally outside Mauritius
Tax residency Depends on applicable residency rules and circumstances Generally resident in Mauritius Generally non-resident when relevant conditions are met
Standard corporate tax Generally 15%, subject to applicable rules Generally 15%, subject to applicable rules Treatment depends on its status, income and applicable legislation
Partial exemption May be available on specified qualifying income May be available on specified qualifying income Do not assume that GBC-style partial exemptions apply
DTA access Potentially available to a qualifying resident company Potentially available, subject to the treaty and relevant conditions Generally not available through Mauritius in the same way as for a qualifying resident company
Management and control Must reflect actual circumstances and applicable law Governance and substance arrangements appropriate to its Mauritius-resident status Must be outside Mauritius
Resident directors Requirements depend on applicable company law Generally at least two suitably qualified Mauritius-resident directors No general requirement for a Mauritius-resident director under the AC framework
Administration Corporate administration and statutory compliance Licensed Management Company and applicable FSC requirements Licensed Management Company acting as registered agent
Reporting Applicable company, tax and audit obligations Applicable FSC, tax, audit and company requirements Annual FSC financial summary and applicable tax obligations
Typical use Local trading, services and operating businesses Cross-border investment and international business where Mauritius residency is appropriate Certain international trading, consultancy and holding arrangements
Mauritius skyline representing structuring decisions for investors
Decision framework

How to choose the right Mauritius company structure.

Selecting a structure requires more than comparing incorporation costs or headline tax rates.

1. Where will the business operate, and where will its income arise? If the business will operate principally in Mauritius, a Domestic Company may be the natural starting point. If its activities are primarily international, a GBC or AC may warrant consideration.

2. Is access to a double taxation agreement important? A GBC may be appropriate where Mauritius tax residency and treaty access are relevant. A Domestic Company may also qualify for treaty benefits if it meets the relevant requirements.

3. Where will central management and control take place? A GBC should maintain governance and substance arrangements consistent with its Mauritius-resident status. An AC must have central management and control outside Mauritius.

4. Can the company maintain the required substance? Assess the personnel, expenditure, governance and operational arrangements needed for its activities — and review them as the business develops.

5. Will the structure remain suitable as the business grows? Considering the next three to five years can reduce unnecessary restructuring, additional costs and potential tax complications.

Scenarios

Four practical examples.

Indicative only — they illustrate how different objectives may influence the choice of structure.

Asian investor into Africa

A GBC may be appropriate if a Mauritius-resident structure supports the investment strategy and treaty access is relevant. Assess DTAs, withholding taxes, beneficial ownership, substance and home-jurisdiction tax treatment.

Consultant living abroad

An AC may warrant consideration if the activity is permitted and ownership, management and control requirements can be satisfied — alongside tax treatment where the company is managed.

Local entrepreneur

A Domestic Company will generally be the natural starting point for a retail or operating business employing local staff and serving Mauritian customers, subject to sector licensing.

Family wealth across borders

Depending on assets and objectives, a GBC, an AC, a trust or a foundation may be considered — individually or in combination. Tailored legal, tax and fiduciary advice is particularly important.

Watchpoints

Common mistakes to avoid.

Structure decisions fail most often when assumptions replace an assessment of the actual business.

Assuming a 3% rate is guaranteed

The 3% figure reflects an 80% partial exemption on qualifying income otherwise taxed at 15%. It applies only to specified categories of income and is conditional.

Expecting treaty benefits from an AC

An AC is generally non-resident for Mauritius tax purposes and does not ordinarily access Mauritius DTAs in the same way as a qualifying tax-resident company.

Treating substance as paperwork

A registered office or formal appointment does not, by itself, demonstrate genuine substance. Governance, personnel, expenditure and decision-making must fit the business.

Choosing only on initial cost

The least expensive structure to establish may not be the most suitable over the long term. Factor ongoing administration, tax consequences and potential restructuring.

FAQ

Frequently asked questions.

Straight answers on GBC, Authorised Company and Domestic Company structures in Mauritius.

A GBC is generally a Mauritius tax-resident structure used for global business, with governance and substance arrangements appropriate to its activities. An AC conducts business principally outside Mauritius and must have central management and control outside the jurisdiction. An AC is generally treated as non-resident for Mauritius income tax purposes when the relevant conditions are met.

An AC is generally not eligible to claim Mauritius DTA benefits in the same way as a qualifying Mauritius tax-resident company. If treaty relief is important to the proposed structure, assess whether a GBC or another qualifying Mauritius-resident vehicle is more appropriate.

The standard corporate income tax rate is generally 15%, subject to applicable exemptions, reliefs and special regimes. Additional taxes or contributions may apply depending on the company's circumstances. The final tax position should be assessed against current legislation rather than relying on the headline rate alone.

No. An effective 3% corporate income tax rate may arise where an 80% partial exemption applies to qualifying income otherwise taxable at 15%. The income must fall within the relevant categories and the applicable conditions must be satisfied. Other taxes or contributions may affect the overall position.

A GBC is generally expected to have at least two suitably qualified directors ordinarily resident in Mauritius, alongside the applicable governance and substance arrangements. The precise requirements should be confirmed for the proposed structure and its activities.

Foreign investment may be possible, subject to the Companies Act and any sector-specific laws, investment approvals, licensing requirements or restrictions relevant to the proposed activity.

A change in structure or regulatory status may be possible, depending on the circumstances, but it should not be assumed to be automatic. It may involve new applications, regulatory approvals, changes to governance and tax consequences. Where a different structure may be needed as the business develops, it is sensible to consider this before incorporation.

Applications for a Global Business Licence and authorisation as an AC must follow the applicable FSC framework through an appropriately licensed Management Company. A Management Company can also assist with corporate administration, regulatory filings and ongoing compliance.

Fideco perspective

Choosing carefully at the outset.

There is no single company structure that is right for every investor. The decision requires a clear understanding of the proposed business, ownership, income flows, governance arrangements and tax implications across all relevant jurisdictions.

At Fideco, we understand that choosing a company structure involves more than incorporation. It means establishing a sound foundation for your business, investments and long-term plans.

Fideco Advisory

Looking to establish a company in Mauritius?

Our advisors help you compare Domestic, GBC and Authorised Company options against your objectives, jurisdictions and substance requirements.

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