Holding Company in Mauritius
Manage investments, subsidiaries, and intellectual property through a Mauritius holding structure.
Mauritius is one of the most established and widely used jurisdictions globally for international holding company structures. The combination of a broad Double Taxation Agreement network (covering over 45 countries), no capital gains tax, no withholding tax on dividends paid to non-resident shareholders, a partial exemption system for qualifying foreign-source income, and a modern, FSC-supervised legal framework makes Mauritius a compelling choice for investors structuring investments across Africa, Asia, and beyond. A Mauritius holding company is typically structured as a Global Business Company (GBC) under the Financial Services Act 2007 and the Companies Act 2001.
The GBC can hold shares in subsidiaries, debt instruments, intellectual property, real estate interests, and other assets. Income received from subsidiaries — including dividends, interest, and royalties — may benefit from reduced withholding taxes under applicable DTAs, and qualifying foreign-source income may further benefit from the 80% partial exemption under the Mauritius tax system, subject to meeting the required economic substance conditions and depending on individual circumstances. For structures where DTA access is not required, an Authorized Company (AC) can serve as a cost-effective holding vehicle.
Mauritius's membership of COMESA, SADC, and the African Continental Free Trade Area (AfCFTA), combined with its strategic geographic location between Africa and Asia, reinforces its position as the premier gateway for investments flowing into and out of the African continent. The Mauritius holding company structure is used by private equity funds, sovereign wealth funds, multinational corporations, family offices, and individual investors worldwide.
Key Features of a Holding Company in Mauritius
Access to 45+ Double Taxation Agreements
A GBC holding company can claim treaty benefits under Mauritius's network of over 45 DTAs, reducing withholding taxes on dividends, interest, and royalties received from subsidiaries in treaty partner countries, subject to substance requirements and individual circumstances.
No Capital Gains Tax
Mauritius does not levy capital gains tax on the disposal of shares, securities, or other investment assets. This is a critical advantage for holding companies planning to exit investments, sell subsidiaries, or realise capital appreciation over time.
No Withholding Tax on Outbound Dividends
Dividends paid by the Mauritius holding company to its non-resident shareholders are not subject to Mauritius withholding tax, enabling efficient upward profit repatriation to ultimate beneficial owners or parent entities.
Partial Exemption on Foreign-Source Income
Qualifying foreign-source income received by a GBC — including foreign dividends, interest, royalties, and gains on disposal of certain securities — may benefit from an 80% partial exemption, potentially reducing the effective tax rate, subject to substance requirements and individual circumstances.
Flexible Asset Holding
A Mauritius holding company can hold a wide range of assets: shares in subsidiaries, shareholder loans, intellectual property, real estate interests, financial instruments, and other investments, all within a single, well-governed legal entity.
Africa and Asia Gateway
Mauritius has DTAs with major African economies and with key Asian markets including India and China. Its COMESA, SADC, and AfCFTA membership provides additional context for investment structures targeting African markets, making Mauritius the premier African holding jurisdiction.
FSC-Supervised and Internationally Credible
FSC licensing and supervision provide the Mauritius holding company with regulatory credibility recognised by institutional investors, co-investors, lenders, and tax authorities in counterparty jurisdictions, supporting banking relationships and investment agreements.
IP Holding and Royalty Structuring
Mauritius holding companies are used to hold intellectual property and receive royalty income from subsidiaries. DTA provisions may reduce withholding taxes on royalties received from treaty partner jurisdictions, subject to substance requirements and anti-avoidance rules in the source country.
Debt Holding and Interest Income
Mauritius holding companies commonly advance shareholder loans to subsidiaries and receive interest income. DTA provisions may reduce withholding taxes on interest received from treaty partner jurisdictions, subject to substance requirements and individual circumstances.
Estate Planning and Succession
High-net-worth individuals use Mauritius holding companies — often in conjunction with a Mauritius trust or foundation — to centralise global assets, facilitate generational wealth transfer, and manage succession planning across multiple jurisdictions.
How to Set Up a Holding Company in Mauritius
Group Structure Analysis and Structuring Advice
We analyse your existing group structure, investment portfolio, and objectives. We recommend the optimal holding arrangement, including whether a GBC or AC is appropriate, the location of the holding company within the group, and the treatment of existing assets or subsidiaries.
DTA Analysis and Tax Planning
We review the applicable DTAs between Mauritius and the relevant counterparty jurisdictions to identify potential withholding tax reductions on dividends, interest, and royalties. We structure income flows to align with substance requirements and applicable anti-avoidance rules.
KYC and Due Diligence Collection
We collect and verify KYC documentation for all beneficial owners, shareholders, and directors. For holding companies with complex group structures, we conduct enhanced due diligence on all entities in the ownership chain.
GBC Incorporation and FSC Licence Application
We incorporate the holding company as a GBC and submit the FSC licence application with a detailed business plan, group structure chart, and substance arrangements. We manage all FSC correspondence and respond promptly to queries.
Substance Arrangements
We establish the substance requirements for the holding GBC: physical registered office, qualified local staff or management services, scheduled board meetings in Mauritius, and adequate operational expenditure. We ensure the structure is positioned to obtain a Tax Residency Certificate from the MRA.
Investment Transfer and Asset Structuring
We assist with the transfer of existing investments or shareholdings into the Mauritius holding company, including coordinating legal and tax advice in the relevant counterparty jurisdictions to ensure transfers are executed efficiently.
Bank Account Opening
We open corporate bank accounts for receiving dividends, interest, royalties, and other holding income. We select banks appropriate for the expected transaction volumes and currency requirements, and prepare comprehensive KYC packs.
Ongoing Administration and Compliance
We provide registered agent, corporate secretary, accounting, annual FSC filings, income tax returns, CRS/FATCA reporting, and Tax Residency Certificate renewal services to maintain the holding structure in good standing on an ongoing basis.
Requirements for a Holding Company in Mauritius
- Comprehensive group structure chart showing all entities and ultimate beneficial ownership
- Certified copies of valid passports for all UBOs, shareholders, and directors
- Proof of residential address (not older than 3 months) for all individuals
- Source of funds and source of wealth documentation for all beneficial owners
- Bank reference letters for all beneficial owners
- Business plan or investment strategy describing the holding company's purpose and activities
- Details of subsidiaries, investments, or assets to be held (jurisdiction, activity, ownership percentage)
- CVs of proposed directors demonstrating relevant experience
- Existing constitutional documents for subsidiaries or entities being held (if applicable)
- Proposed company name (three alternatives recommended)
- Evidence of proposed substance arrangements (office lease, staffing, management agreement)
Estimated Costs of a Holding Company in Mauritius
| Item | Estimated Range |
|---|---|
| GBC holding company incorporation and FSC licence (year 1) | USD 4,000 – 7,000 |
| Annual registered agent and corporate secretary (per annum) | USD 2,000 – 4,000 |
| Accounting and financial statements (per annum) | USD 2,500 – 6,000 |
| Tax Residency Certificate application (MRA) | USD 300 – 600 |
| Substance management (local director, board meetings) | USD 2,000 – 5,000 |
| Bank account opening assistance | USD 500 – 1,500 |
| AC holding company formation and FSC registration (year 1, alternative) | USD 2,500 – 4,000 |
Frequently Asked Questions About Holding Company in Mauritius
Why is Mauritius a preferred jurisdiction for holding companies?
Mauritius combines no capital gains tax, no withholding tax on outbound dividends, access to 45+ Double Taxation Agreements, a partial exemption system for qualifying foreign-source income, FSC regulatory oversight, and a strategic location between Africa and Asia. These features make it one of the most attractive and widely used holding company jurisdictions globally, particularly for African and Asian investments.
Can a Mauritius holding company hold investments across Africa?
Yes. Mauritius is one of the most commonly used jurisdictions for holding African investments. It has DTAs with key African economies, is a member of COMESA, SADC, and the AfCFTA, and is well understood by African regulators and counterparties. Many leading private equity funds, development finance institutions, and multinational groups use Mauritius as their African holding platform.
What economic substance does a holding GBC need to demonstrate?
A holding GBC must be managed and controlled from Mauritius, with board meetings held locally with a majority of Mauritius-based directors. It must maintain a physical registered office, employ qualified staff (or engage qualified service providers) commensurate with its holding activities, and incur adequate operational expenditure in Mauritius. The specific requirements depend on the scale and nature of the holding activities.
Is there withholding tax on dividends paid up from a Mauritius holding company?
No. Dividends paid by a Mauritius company — including a GBC holding company — to its non-resident shareholders are not subject to Mauritius withholding tax. This enables efficient upward repatriation of income from the holding company to its ultimate beneficial owners or parent entities.
Can a Mauritius holding company hold intellectual property?
Yes. Mauritius holding companies are used to hold intellectual property and receive royalty income from subsidiaries or licensees. Applicable DTA provisions may reduce withholding taxes on royalties received from treaty partner jurisdictions, subject to substance requirements, anti-avoidance rules in the source country, and individual circumstances.
How is dividend income received by the holding company taxed?
Foreign-source dividends received by a GBC may benefit from an 80% partial exemption under the Mauritius tax system, subject to meeting substance requirements. The effective tax rate on such income may therefore be below the standard 15% rate, depending on individual circumstances. We recommend obtaining specific tax advice on your particular structure.
Can the Mauritius holding company also hold debt instruments?
Yes. A Mauritius holding company can advance shareholder loans to subsidiaries and hold debt instruments, receiving interest income. Applicable DTA provisions may reduce withholding taxes on interest received from treaty partner jurisdictions, subject to substance requirements and individual circumstances.