A GBL1 can be set up to carry out any global business activities or such other financial business activities as may be approved by the Financial Services Commission. This may include Assets Management, Credit Finance, Custodian services (non-CIS), Distribution of financial products, Factoring, Leasing, Occupational Pension Scheme, Pension fund administrators, Pension Scheme Management, Retirement Benefits Scheme, Superannuation Funds, Registrar and Transfer Agent and Treasury Management.
Existing Requirements for GBC1
Currently, the FSC considers the following when determining whether the conduct of business is managed and controlled from Mauritius:
- The corporation shall have or has at least 2 directors, resident in Mauritius, who are appropriately qualified and are of sufficient calibre to exercise independence of mind and judgement
- The corporation shall maintain or is maintaining at all times its principal bank account in Mauritius
- The corporation shall keep and maintain or is keeping and maintaining, at all times, its accounting records at its registered office in Mauritius
- The corporation shall prepare, or proposes to prepare or prepares its statutory financial statements and causes or proposes to have such financial statements to be audited in Mauritius
- The corporation shall provide or provides for meetings of directors to include at least 2 directors from Mauritius
- A corporation which is authorised/licensed as a collective investment scheme, closed end fund or external pension scheme, is administered from Mauritius
The FSC issued new substance guidelines for global business companies and these are to be effective as from 1 January 2015. Going forward, in addition to the existing conditions, a GBC1 would need to fulfil AT LEAST ONE of the following criteria:
- The corporation has or shall have office premises in Mauritius
- The corporation employs or shall employ on a full time basis at administrative/technical level, at least one person who shall be resident in Mauritius
- The corporation’s constitution contains a clause whereby all disputes arising out of the constitution shall be resolved by way of arbitration in Mauritius
- The corporation holds or is expected to hold within the next 12 months, assets (excluding cash held in bank account or shares/interests in another corporation holding a Global Business Licence) which are worth at least USD 100,000 in Mauritius
- The corporation’s shares are listed on a securities exchange licensed by the Commission
- It has or is expected to have a yearly expenditure in Mauritius which can be reasonably expected from any similar corporation which is controlled and managed from Mauritius
Double Taxation Avoidance Agreements – DTAAs
A Global Business Licence 1 qualifies as tax resident in Mauritius and thus benefit from the Double Taxation Avoidance Agreements that Mauritius has established. It is taxed at 15% on its chargeable income but it may claim a foreign tax credit of 80%, thus resulting in a maximum effective tax rate of 3%.
foreign tax credit
effective tax rate
Our Legacy Team is help you to establish your fiscal structures and to make full use of the DTAAs in place. You are invited to contact us for more information regarding structuring and fiscal optimization. However, if you would wish to go ahead and download the DTAAs, they are available below.
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People's Republic of China
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|State of Qatar||Swaziland||Sweden (New)|
Legacy Capital has a number of multinational clients and international groups, particularly focusing on Africa and reputed in their field of business, and which are seeking to expand their footprint in the Mauritius International Financial Centre through having their regional headquarters based here.
We will structure their holding entities in Mauritius, and define the parameters for the entities to provide headquarter services to their subsidiaries operating in other countries, such as administration and general management; business planning and economic or investment research, amongst others.
Within the same spirit, Legacy Capital will also provide solutions to establish treasury management activities of its multinational clients in Mauritius, and trigger the tax incentives provided to the Global Treasury Activities Licence.
The activities of the treasury management entity would consist of arrangement for credit facilities and derivatives, corporate finance advisory, credit administration and control and management of funds for designated investments, amongst others.
Our personnel boast sufficient proven expertise and track record in the above-mentioned activities. Legacy Capital will also leverage on its privileged relationship with local banks to provide activities like re-invoicing and letters of credits to its regional treasury management services entities.
Get in touch
Legacy Capital is helping its esteemed clients worldwide to do business. If you have any questions about our service offerings, please email us using our contact form and our dedicated team will reply to your queries