Protected Cell Company (PCC)

A Protected Cell Company (PCC) is a single legal entity made of a Core and several Cells with separate assets and liabilities.

A single legal entity that operates segregated accounts, or Cells, each of which is legally protected from the liabilities of the company’s other accounts. Despite the segregation of assets and liabilities that exists between the Cells and the Core and among the Cells themselves, a Cell has no separate legal identity.

An individual client’s account is insulated from the gains and losses of other accounts, such that the PCC sponsor and each Cell is protected against liquidation activities by creditors in the event of insolvency of another Cell.

At a glance

Significant Features

Different cells are taxed separately.
Favourable tax treatment under the double taxation avoidance agreements whilst being taxed as a single entity.
Legal segregation and protection of assets and liabilities for each cell.
May be incorporated, continued or converted from an existing company.
No minimum capital requirement is imposed for the PCC and each cell except for insurance business.
Taxed as a GBC1 company, thus benefitting from the corporate tax incentive.
Unlimited number of cells may be provided, with each cell having its own name or designation.
Useful for any investment entity with various investment portfolios where each has its own investment strategy.

Purposes

Legally separate the assets of life, pension and individual policyholders.
The assets of life insurance business need to be legally separated from those of non-life business.
Several cells are established, each holding a particular insurance exposure of the parent and segregated.
Insurers or reinsurers can accommodate the differing needs of clients.
Reinsurance contracts and securitization issues can be placed within separate cells.
Companies can operate their captive insurance, treasury and other functions globally in a single entity using the same core capital.
Captive insurance companies – segregate distinct areas of risk and activity into different cells.
The owners of the PCC can offer capital financing to clients

Tax Structure

A PCC is liable to Mauritian income tax at the rate of 15% which may be reduced to 0% after application of the provisions on foreign tax credit.

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Protected Cell Company (PCC)

At a glance

Significant Features

Purposes

Tax Structure

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