Regulatory Framework

Initially called the Category 1 Global Business Licence Company (commonly known as GBC1 / GBL1) until the promulgation of the Finance Act 2018, whereafter a new entity was introduced, namely the Global Business Corporation (GBC) with similar features as the GBC1:

• The GBC is a Mauritius tax resident company limited by shares and governed by the Mauritius Companies Act. The GBC is issued with a Global Business Licence by the FSC in accordance with the Financial Services Act. 
• The activities of a GBC are usually conducted outside of Mauritius. However, the GBC has to comply with certain substance requirements in order to satisfy its tax residency status in Mauritius, and to avail of the benefits of Double Taxation Avoidance Treaties that Mauritius has signed with over 40 countries.
• The GBC can be used for holding, trading or consultancy activities.
• Following reforms introduced by the Finance Act in 2018 and 2019, the effective corporate tax rate of the GBC will be determined by its activities: e.g. Holding (0% – 3%), Trading (3%) and Consulting (15%).

Previously, the FSC allowed the incorporation of “Category 2” Global Business Licence Companies (GBC2/GBL2).  However, further to the tax reforms published in 2018/2019, no new GBC2 licences have been issued by the FSC and by 30^th of June 2021, all GBC2 Licence companies will have to be converted to either a GBC or a Domestic company.

As a result of the tax reforms, a new entity was introduced, namely the “Authorised Company” (AC).  Both the old GBC2 and the new AC structures are exempt of corporate taxation in Mauritius.  However, the AC has to be centrally managed and controlled out of Mauritius in order to be exempt from corporate taxation.

The AC can be used for trading or consulting services, or any authorized activity as determined by the FSA.

A Protected Cell Company (PCC) is a company that is a single legal entity, but which may be segregated into separate cells, such that the assets and liabilities of each cell are legally separate from the assets and liabilities of any other cell.

PCCs in Mauritius are governed by the Protected Cell Companies Act of 1999, and are mainly used for asset holding, structured finance business, collective investment schemes and closed-end funds, insurance business and external pension schemes.  A PCC simplifies the overall administration of the entities and reduces the cost of operation.

A Collective Investment Scheme (CIS) will be incorporated under the laws of Mauritius as a private company with limited liability, and will have to be licensed as a “Global Business Corporation” by the FSC and in terms of the Mauritius Financial Services Act of 2007.  

The CIS will also have to seek authorization from the FSC, under the Securities Act of 2005, to operate as a closed-ended fund and pursuant to the Securities (Collective Investment Schemes and Closed-ended Funds) Regulations 2008 to operate as a Professional Collective Investment Scheme (PCIS).