Global Business Company
A Global Business Company holds a Global Business Licence from the Financial Services Commission and conducts business principally outside Mauritius while being managed and controlled from within it. It is the structure for holding companies, international trading, investment funds and regional headquarters that want access to Mauritius's double taxation agreements.
Global Business Companies are licensed by the Financial Services Commission and must be administered by a licensed Management Company. These engagements are delivered with our sister company, Intrasia Management (Mauritius) Limited, which holds a Management Licence from the FSC. start.mu coordinates the engagement on the client's behalf.
At a glance
| Licence | Global Business Licence issued by the Financial Services Commission |
|---|---|
| Administration | Must be administered by a Management Company licensed by the FSC |
| Substance | At least two resident directors, a principal bank account in Mauritius, accounts kept and audited in Mauritius, board meetings held in Mauritius, and core income-generating activity carried out in Mauritius |
| Tax | 15% with an 80% partial exemption on qualifying foreign-source income, giving an effective rate of 3% on that income, subject to substance |
| Treaty access | Eligible for Mauritius's network of double taxation agreements, subject to tax residence certification |
| Timing | Licensing typically takes several weeks from a complete file |
Who it suits
A business owner with operations or investments in several countries, particularly in Africa and Asia, who wants a stable, well-regulated holding jurisdiction with treaty access. It is not the right structure for a business that will trade principally in Mauritius, and it is not a structure for a permit application on its own, although a Global Business Company can employ a Professional permit holder.
Substance is not optional
The value of a Global Business Company lies in its tax residence, and tax residence depends on real management and control in Mauritius. The FSC and the Mauritius Revenue Authority test this. Directors must be resident and must actually direct. Decisions must be made in Mauritius. Expenditure and staff must be proportionate to the activity. We set the structure up so that it can meet these tests, and we say so plainly where a proposed structure cannot.
How we work on these engagements
We assess the proposal, identify the right licence and structure, and coordinate the application through the licensed Management Company. Where the owner is also relocating, we run the permit and the personal side in parallel so that the two are consistent.
Questions we are asked
Is a Global Business Company right for a business that trades in Mauritius?
No. It is for business conducted principally outside Mauritius. A business serving the Mauritian market uses a Domestic Company.
What does substance mean in practice?
Two resident directors who actually direct, board meetings held in Mauritius, a principal bank account and audited accounts here, and core income-generating activity carried out in Mauritius with expenditure and staff proportionate to it. The tax residence, and therefore the value of the structure, depends on it.
Can a Global Business Company support my Occupation Permit?
It can employ a Professional permit holder. It is not, on its own, the vehicle for an Investor permit, which assumes a business generating revenue in Mauritius.
Tell us what the business will do
The right structure follows from the activity, the owners and where the customers are. Describe those three things and we will set out the structure, the costs and the sequence in a written proposal.