This license (issued by the FSC; to holding companies incorporated in Mauritius) allows multinational companies to set up their regional administration, procurement and accounting offices within the Mauritius International Financial Centre (IFC). It also enables them to provide headquarter services such as administration and general management; which includes business planning, development and coordination; and economic and investment research and analysis, to its subsidiaries operating in other countries.
ADVANTAGES OF THE MAURITIUS REGIONAL HEADQUARTER
Acting as a Mauritius Regional Headquarter (MUHQ) for the African region, the structure will assume responsibility for the overall purchases, sales and distributions of machineries, equipment, supplies, software, hardware, and others from around the world for its African subsidiaries. This will enable cost optimisation, discounted pricing for purchases in bulk and cash flow management.
More importantly, sales and distributions made to the African network will be at a mark-up enabling the Mauritius Headquarter to maximise profit retention in Mauritius and thereby maximising the fiscal optimisation benefits of this group.
The MUHQ can be used to employ expatriates that will work across the continent. This will present numerous benefits, such as:
- For the expatriates
They will benefit from low personal taxes as they will be issued with an Occupation Permit*.
- For the billing of the subsidiaries
The MUHQ will be able to bill the subsidiaries on hourly/daily basis for use of those professionals at end-market levels.
IP rights (License Agreement)
The MUHQ develops processes, copyrights, patents, trademarks and trade secrets. The Legacy team can assist with the registration of IP, patents & trademarks with the relevant authorities.
The MUHQ will hold Intellectual Property rights in Mauritius. The GBC1 company will in turn assign those rights to the end-market subsidiaries. Consequently, the end-market subsidiaries will have to pay royalties by virtue of a license agreement* for the use of the Intellectual Property rights (Trademarks and other Copyrights) that have been assigned to the respective African companies.)
After the 8 years’ tax holiday, the MUHQ will be subject to an effective tax rate of 0% to 3%. The Corporate Income Tax at the incentive taxation rate of 15%, has the added fiscal benefit of being subject to a deemed foreign tax credit of 80% of the 15% charged making the maximum effective rate of tax at 3%. There are no Mauritius capital gains tax, dividend or interest withholding taxes in Mauritius.
Mauritius is undeniably a superior investment structuring financial centre than foreign jurisdictions like Guernsey, Jersey and Isle of Man, especially where countries targeted for investments have signed a tax treaty with Mauritius. Mauritius has a network of about 43 tax treaties.
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