The choice between a Global Business Company (GBC) and an Authorized Company (AC) is one of the most fundamental decisions in Mauritius corporate structuring. Both are regulated by the Financial Services Commission (FSC) under the Financial Services Act 2007 and are designed for entities conducting business predominantly outside Mauritius. However, they differ profoundly in their tax status, DTA access, regulatory requirements, substance obligations, and suitability for different purposes.
Understanding these differences — and choosing correctly — is critical for achieving your tax and operational objectives. The GBC is a tax resident entity in Mauritius, subject to the 15% corporate tax rate with the benefit of the partial exemption system and, most critically, access to Mauritius's network of 45+ Double Taxation Agreements. It is the appropriate structure when DTA access, tax residency certificates, or a reduced effective tax rate on foreign-source income are objectives.
The AC, by contrast, is not tax resident in Mauritius and cannot access DTAs. It is not subject to Mauritius income tax on foreign-source income. The AC has lighter regulatory requirements and lower costs than the GBC.
It is the appropriate structure for holding companies, international trading entities, IP holding vehicles, and treasury operations where DTA benefits are not required. Both entities require a licensed management company as their registered agent and are incorporated under the Companies Act 2001.
Tax Residency
The GBC is a tax resident entity in Mauritius. It is treated as resident for tax purposes under the Income Tax Act and can access the benefits of Mauritius's 45+ Double Taxation Agreements. It is subject to the 15% corporate tax rate, with the partial exemption system potentially reducing the effective rate on qualifying foreign-source income to as low as 3%. The AC is not tax resident in Mauritius. It is not subject to Mauritius income tax on income derived from outside Mauritius. It cannot claim DTA benefits.
DTA Access
This is the most fundamental distinction. Only the GBC, as a tax resident entity, can access Mauritius's Double Taxation Agreement network. A Tax Residency Certificate (TRC) from the MRA is required to claim treaty benefits. The AC has no access to DTAs. This makes the GBC the mandatory choice for any structure where reducing withholding taxes on dividends, interest, or royalties from treaty partner countries is an objective.
Substance Requirements
The GBC must demonstrate economic substance in Mauritius to maintain its licence and access the partial exemption system. Substance requirements include: management and control exercised from Mauritius (board meetings held in Mauritius, majority of directors resident in Mauritius), adequate qualified employees, physical office presence, and adequate expenditure in Mauritius commensurate with the level of activity. The AC does not have prescribed economic substance requirements. However, it must maintain a licensed management company as its registered agent, which provides a basic level of local administration.
Regulatory Requirements
The GBC requires a full FSC Category 1 Business Licence, involving a comprehensive application, detailed business plan, fit-and-proper assessment of directors and beneficial owners, and ongoing FSC supervision including annual compliance certificates and substance evidence. The AC requires FSC registration (rather than full licensing), with a simpler application process, lighter ongoing obligations, and no annual substance reporting. Both require annual returns to the Registrar of Companies.
Cost Comparison
GBC formation costs typically range from USD 5,000–12,000 (year one, excluding nominees). Annual maintenance is approximately USD 8,000–20,000+. AC formation typically costs USD 2,000–5,000, with annual maintenance of USD 3,000–8,000. The cost differential reflects the GBC's more extensive regulatory requirements, substance obligations, and annual compliance burden.
Suitable Use Cases
Choose a GBC for: investment holding companies routing dividends or capital gains from DTA jurisdictions (particularly Africa and India), fund structures requiring tax residency, IP holding and royalty collection from DTA partners, intercompany lending where treaty interest reduction is valuable, and structures requiring a MRA Tax Residency Certificate. Choose an AC for: holding company structures where no DTA access is needed, international trading companies where tax is managed in the country of operations, IP holding without royalty flows requiring treaty access, treasury and finance vehicles, and structures where cost minimisation is the primary objective.
GBC vs Authorized Company — Side-by-Side Comparison
| Feature | Global Business Company (GBC) | Authorized Company (AC) |
| Tax Residency | Yes — tax resident in Mauritius | No — not tax resident |
| DTA Access | Yes — 45+ treaties | No |
| Corporate Tax Rate | 15% (effective rate potentially 3% on qualifying income) | Not subject to Mauritius income tax on foreign income |
| Partial Exemption | Yes — 80% on qualifying foreign income | Not applicable |
| Capital Gains Tax | None | None |
| FSC Requirement | Full FSC Licence required | FSC Registration required |
| Substance Requirements | Yes — directors, employees, office, expenditure | No prescribed substance |
| Management Company | Required | Required |
| Bank Account Opening | Generally easier | May face additional scrutiny |
| Annual Compliance | More extensive (substance evidence, compliance certificate) | Lighter obligations |
| Formation Cost (approx.) | USD 5,000–12,000 | USD 2,000–5,000 |
| Annual Cost (approx.) | USD 8,000–20,000+ | USD 3,000–8,000 |
| Best For | DTA investment, treaty access, partial exemption | Holding, trading, IP, treasury without DTA need |
The information on this website is for general informational purposes only and does not constitute legal, tax, or financial advice. Each situation is unique — please consult qualified professionals before making decisions.
