GBC1 Company

A GBC1 can carry out any financial or non-financial business activity, e.g., investment holding, asset management, credit finance, custodian services (non-CIS), distribution of financial products, factoring, leasing, occupational pension schemes, pension fund administration, pension scheme management, retirement benefits schemes, superannuation funds, registrar and transfer agencies, treasury management and such other financial business activities as may be specified by the Financial Services Commission (FSC), the non-banking financial activities regulator.

At a glance

Significant features

Can either be a private company, a public company or a foreign company registered under the companies’ Act of 2001.

Company may be limited by share or guarantee, or by both.
Open bank accounts in local and foreign currencies.
Claim double taxation relief under the various treaties signed by Mauritius.
Can conduct business in Mauritius, deal with a person resident in Mauritius and can hold shares or other interests in a corporation resident in Mauritius.
Audited accounts filed within 3-6 months after year end.

Tax advantages

A GBC1 is considered to be tax resident in Mauritius and is subject to corporate tax at 15%. However, a GBC 1 may claim a foreign tax credit in respect of the actual foreign tax suffered or 80% presumed tax credit, whichever is higher and this brings about for a GBC 1 to have a maximum effective tax rate of 3%.
Other tax advantages for GBC 1 in Mauritius are that there is:
- no capital gains tax
- no withholding tax on dividends, interest and royalties paid
- no stamp duties
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 GBC1.
A GBC1 wishing to benefit from the tax relief under the Double Taxation Agreements requires a Tax Residence Certificate (TRC).

Regulatory Requirements

In order to obtain a tax residence certificate, a company must demonstrate that the business is being controlled and managed from Mauritius. This is known as the Control and Management Test. The five criteria’s to pass the control and management test are that the GBC1:

Have at least 2 directors resident in Mauritius.
Maintain its principal bank account in Mauritius.
Keep and maintain its accounting records at its registered office in Mauritius.
Statutory financials, to be audited in Mauritius.
Board meetings held in Mauritius.

Regulatory Requirements cont.

In addition to existing substance requirements, at least two of the following additional criteria must also be met:

Have office premises in Mauritius; or
Employ one person who shall be resident in Mauritius.
Constitution should contain a clause whereby all disputes arising out of the constitution shall be resolved by way of arbitration in Mauritius; or
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; or
Shares are listed on a securities exchange licensed by the FSC; or
Have a yearly expenditure in Mauritius which can be reasonably expected from any similar corporation which is controlled and managed from Mauritius.

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GBC1 Company

At a glance

Significant features

Tax advantages

Regulatory Requirements

Regulatory Requirements cont.

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GBC1 Company

GBC1 Company

At a glance

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