Global Business Company (GBC)
Access 45+ Double Taxation Agreements and a world-class regulatory framework.
The Global Business Company (GBC) is the flagship corporate vehicle for international business conducted from Mauritius and one of the most widely used structures by multinational groups, private equity sponsors, fund managers, and high-net-worth investors seeking access to the African and Asian markets. Licensed by the Financial Services Commission (FSC) under the Financial Services Act 2007, and incorporated under the Companies Act 2001, the GBC is specifically designed for entities that conduct business predominantly outside Mauritius. The GBC is tax resident in Mauritius and can therefore access the country's extensive network of over 45 Double Taxation Agreements (DTAs) with key trading and investment partners across Africa, Asia, Europe, and beyond.
The standard corporate tax rate applicable to a GBC is 15%. A partial exemption system exists under which an 80% exemption may apply to qualifying categories of foreign-source income — such as foreign dividends, interest, royalties, and gains on the disposal of certain securities — which may result in a reduced effective tax rate, subject to meeting the required economic substance conditions and individual circumstances. GBCs must demonstrate genuine economic substance in Mauritius, including management and control from Mauritius, qualified local staff, a physical office, and adequate operational expenditure.
The FSC supervises GBCs on an ongoing basis, ensuring compliance with licence conditions, AML/CFT obligations, and international regulatory standards. Mauritius GBCs are widely accepted by international banks, institutional investors, and counterparties globally.
Key Features of a Global Business Company (GBC) in Mauritius
Access to 45+ Double Taxation Agreements
As a tax resident entity, the GBC can claim treaty benefits under Mauritius's network of over 45 DTAs, reducing withholding taxes on dividends, interest, and royalties received from treaty partner jurisdictions, subject to satisfying substance requirements.
Partial Exemption on Foreign-Source Income
An 80% partial exemption may apply to qualifying foreign-source income categories — including foreign dividends, interest, royalties, and gains on disposal of securities — potentially reducing the effective tax rate below the standard 15%, subject to substance conditions and individual circumstances.
FSC Licensing and Regulatory Credibility
The GBC is licensed and supervised by the Financial Services Commission under the Financial Services Act 2007. FSC oversight provides international credibility, facilitates banking relationships, and demonstrates regulatory compliance to counterparties and investors.
Tax Residency Certificate
The Mauritius Revenue Authority (MRA) issues a Tax Residency Certificate (TRC) to eligible GBCs, confirming their residence status for DTA purposes. This document is required when claiming treaty benefits in counterparty jurisdictions.
No Capital Gains Tax
Mauritius imposes no capital gains tax on the disposal of shares, securities, or other investment assets. This makes the GBC particularly attractive as a holding vehicle for exits, share sales, and investment disposals.
No Withholding Tax on Outbound Dividends
Dividends paid by a GBC to its non-resident shareholders are not subject to Mauritius withholding tax, enabling efficient profit repatriation to foreign investors and parent companies.
Economic Substance Requirements
GBCs must demonstrate adequate substance in Mauritius: management and control from Mauritius, board meetings held locally, qualified employees or service providers, a physical registered office, and adequate operational expenditure commensurate with activities.
Flexible Corporate Structure
The GBC can be structured with various share classes, directors, and governance arrangements under the Companies Act 2001, and can hold subsidiaries, real estate, debt instruments, intellectual property, and other assets.
Africa and Asia Gateway
Mauritius has DTAs with major African economies — including South Africa, Kenya, Zimbabwe, Mozambique, and others — as well as India, China, and key Asian markets. The GBC is the preferred vehicle for investments flowing into and out of these regions.
International Banking Access
GBCs benefit from access to a well-developed banking sector, including international banking groups with Mauritius operations. Corporate bank accounts can be opened with local and correspondent banks, facilitating multi-currency transactions.
How to Register a GBC in Mauritius
Initial Assessment and Treaty Analysis
We review your business model, investment flows, target markets, and treaty requirements to confirm that the GBC is the optimal structure. We identify applicable DTAs and analyse the potential tax benefits available, subject to substance and individual circumstances.
KYC and Due Diligence Collection
We collect and verify KYC documentation for all beneficial owners, shareholders, directors, and other relevant parties. This includes certified passport copies, proof of address, source of funds and source of wealth declarations, CVs, and bank reference letters.
Business Plan and Application Preparation
We prepare a detailed business plan describing the GBC's proposed activities, target markets, income flows, and substance arrangements. We compile the full FSC licence application with all supporting documentation.
FSC Licence Application and Company Registration
We submit the GBC licence application to the FSC and simultaneously file the company incorporation documents with the Registrar of Companies under the Companies Act 2001. We manage all regulatory correspondence and respond promptly to FSC queries.
Substance Arrangements
We assist in establishing the substance requirements: arranging a physical registered office, confirming qualified local staff or outsourced management, and setting up board meeting schedules in Mauritius to demonstrate management and control.
Licence Issuance and Certificate Delivery
Upon FSC approval, the GBC licence is issued. We obtain the Certificate of Incorporation and deliver all formation documents, corporate registers, and the FSC licence certificate to the client.
Bank Account Opening
We facilitate corporate bank account opening with a Mauritius-based or international bank, preparing the bank KYC pack and liaising with relationship managers. Multi-currency accounts can be arranged to support international transaction flows.
Ongoing Compliance and Substance Management
We provide registered agent, corporate secretary, accounting, annual FSC filings, and tax compliance services to maintain the GBC in good standing. We also assist with obtaining Tax Residency Certificates from the MRA for DTA claim purposes.
Requirements for a GBC in Mauritius
- Certified copies of valid passports for all beneficial owners, shareholders, and directors
- Proof of residential address (utility bill or bank statement, not older than 3 months) for all individuals
- Completed KYC forms and beneficial ownership declarations for all stakeholders
- Detailed business plan describing proposed activities, target markets, and expected income flows
- Source of funds declaration and supporting documentation for all beneficial owners
- Source of wealth declaration and supporting documentation for all beneficial owners
- Bank reference letters for all beneficial owners (on bank letterhead, signed by a bank officer)
- CVs or professional profiles of proposed directors demonstrating relevant experience and qualifications
- Group structure chart showing all related entities and ultimate beneficial ownership
- Evidence of proposed substance arrangements (draft office lease, employment terms, or management agreement)
- Details of any proposed regulated activities requiring additional FSC licence categories
- Proposed company name (three alternatives recommended)
Estimated Costs of a GBC in Mauritius
| Item | Estimated Range |
|---|---|
| GBC incorporation and FSC licence application (year 1) | USD 4,000 – 7,000 |
| Registered office and registered agent (per annum) | USD 1,500 – 2,500 |
| Corporate secretary and annual FSC filings (per annum) | USD 1,500 – 3,000 |
| Accounting and financial statements preparation (per annum) | USD 2,000 – 5,000 |
| Tax Residency Certificate application (MRA) | USD 300 – 600 |
| Bank account opening assistance | USD 500 – 1,500 |
| Substance management (local director, board meetings) | USD 2,000 – 5,000 |
Frequently Asked Questions About Global Business Company (GBC)
What is the difference between a GBC and an Authorized Company?
A GBC is licensed by the FSC, is tax resident in Mauritius, and can access Double Taxation Agreements, making it suitable for international operations requiring treaty benefits. An Authorized Company (AC) is registered with the FSC but is not tax resident in Mauritius, cannot access DTAs, and has lighter substance and compliance requirements. The AC is suitable for holding, trading, or treasury activities where DTA access is not required.
What substance requirements must a GBC satisfy?
A GBC must demonstrate management and control from Mauritius, including holding board meetings locally with a majority of Mauritius-based directors, maintaining a physical registered office, employing qualified staff (or engaging qualified service providers) commensurate with its activities, and incurring adequate operational expenditure in Mauritius. The specific requirements depend on the nature and scale of the GBC's business.
How is a GBC taxed in Mauritius?
GBCs are subject to the standard Mauritius corporate tax rate of 15% on their net income. Qualifying foreign-source income categories — including foreign dividends, interest, royalties, and certain capital gains — may benefit from an 80% partial exemption, potentially resulting in a lower effective rate on those income streams, subject to meeting substance requirements and individual circumstances. There is no capital gains tax or withholding tax on dividends paid to non-residents.
Can a GBC access the Mauritius-India Double Taxation Agreement?
The Mauritius-India DTA has been amended following a 2016 protocol, and capital gains on Indian investments made by Mauritius GBCs after 1 April 2017 are now taxable in India. Interest and dividend provisions may still provide benefits depending on the structure. We recommend obtaining specific tax advice tailored to your India-related investment strategy.
How long does it take to obtain a GBC licence?
The FSC typically processes GBC licence applications within 2–4 weeks of receiving a complete and compliant application. Incomplete applications or those requiring additional information may take longer. Our team ensures that all documentation is prepared thoroughly to minimise processing time.
Can a GBC conduct business in Mauritius?
A GBC is intended to conduct business predominantly outside Mauritius. It should not conduct business with Mauritius residents or engage in domestic activities. If you need to conduct both domestic and international business, a separate domestic company or a different structure may be required.
What annual filings does a GBC need to make?
A GBC must file an annual financial summary with the FSC, maintain up-to-date beneficial ownership information, file income tax returns with the MRA, comply with CRS and FATCA reporting obligations, and renew its FSC licence annually. Our compliance team manages all of these obligations on your behalf.
Can a GBC hold a subsidiary in another country?
Yes. A GBC is commonly used as a holding company for subsidiaries in Africa, Asia, and other regions. It can hold shares, debt instruments, and other interests in foreign entities. The applicable DTA may reduce withholding taxes on dividends, interest, and royalties received from those subsidiaries, subject to substance requirements and individual circumstances.