• Exempted capital gains tax in Mauritius;
• Eligible for tax sparing benefits;
• If shareholding paying dividend in the GBC is directly/indirectly >5%, eligible to underlying tax credit on dividend;
• A GBC is considered to be tax resident in Mauritius and is subject to corporate tax at 15%. However, a partial tax exemption of 80% will apply on specific types of income including:

– Foreign-source dividends derived by a company;

– Interest derived from overseas by a company other than a bank;

– Profit attributable to a permanent establishment of a resident company in a foreign country;

 – Foreign-source income derived by a collective investment scheme (CIS), closed-end fund, CIS manager, CIS administrator, investment adviser or asset manager, licensed or approved by the Financial Services Commission; and

– Income derived from overseas by companies engaged in ship and aircraft leasing.

Where a company has claimed the partial exemption, no credit for foreign taxes in the form of actual tax credit, underlying tax credit and tax sparing credit will be available. The definition of foreign-source income has been changed to “income which is not derived from Mauritius”.

• The expanding network of DTAs has further reinforced Mauritius as a tax efficient jurisdiction and is also one of the prime reasons explaining the growing investment in GBCs.
• A GBC wishing to benefit from the tax relief under the Double Taxation Agreements requires a Tax Residence Certificate (TRC).