Category 1 Global Business Companies (GBC1)

A GBC1 is a body corporate registered in Mauritius and which is licensed by the Financial Services Commission as holding a Category 1 Global Business Licence to conduct business outside Mauritius.

A GBC 1 may either be locally incorporated or be registered as a branch of a foreign company. A foreign company may be redomiciled and continue as a Mauritian GBC1, if the foreign law so permits. There is no minimum or maximum capital requirement and the share capital can be expressed in any currency other than the Mauritian Rupee.

With the coming into operation of the Finance Act 2010, a GBC1 company is not prevented from (i) carrying on business in Mauritius, (ii) dealing with persons resident in Mauritius, and (iii) holding shares or other interests in a corporation which is resident in Mauritius.

A GBC1 may conduct any business activity to the extent that it is not unlawful or contrary to public interest and to the extent that it does not cause or is likely to cause serious prejudice to the good repute of Mauritius as a centre for financial services.

A GBC1 should be administered at all times by a Management Company and should be controlled and managed in Mauritius.

The following indicative list of criteria has to be complied with:

  1. The company must have at least 2 directors, resident in Mauritius, of sufficient calibre to exercise independence of mind and judgement.
  2. The company will maintain at all times its principal bank account in Mauritius.
  3. The company will keep and maintain at all times its accounting records at its registered office in Mauritius.
  4. The company will prepare its statutory financial statements and cause same to be audited in Mauritius.
  5. The company will provide for meetings of directors to include at least 2 directors from Mauritius.
A GBC1 is tax resident in Mauritius and can therefore benefit from the network of Double Taxation Avoidance Agreements (DTAAs) which Mauritius has in place with a number of countries.

Corporate tax in Mauritius is at 15% and GBC1 is entitled to a tax credit equivalent to the higher of the actual foreign tax suffered (underlying tax) or 80% of the Mauritius tax on its foreign source income. With an applicable tax rate of 15%, combined with a foreign tax credit of 12% (80% x 15%) the effective tax rate for the GBC1 will be a maximum of 3%.

There are no capital gains taxes, nor exchange control

Potential uses of a GBC1

A GBC1, being tax resident in Mauritius is the ideal structure for investment and investment holding purposes.  Besides benefitting from the network of Double Taxation Avoidance Agreements in place, it also benefits from the absence of capital gains tax and reduced withholding taxes on payment of royalties and dividends abroad.

A GBC1 can be used to hold intellectual property rights such as copyright, industrial designs, patents, trademarks, service marks and other collective marks.