Global Business Corporation (GBC)
Company formation in Mauritius
The GBC is best suited for: Holding companies for investments into India and Africa, Private equity and venture capital fund structures, International trading companies routing through a treaty-friendly jurisdiction, Family offices and wealth management structures. A GBC is taxed at the standard Mauritius corporate tax rate of 15%. However, foreign-source income qualifies for an 80% partial exemption, resulting in an effective tax rate of approximately 3%. To qualify, the company must be centrally managed and controlled in Mauritius, employ (directly or through its management company) a reasonable number of qualified persons, and incur a minimum annual expenditure in Mauritius proportionate to its activities. The company must demonstrate that it is not established to serve as a conduit for treaty benefits. There is no capital gains tax. Withholding tax on dividends paid by a GBC to non-residents is 0%. Audited financial statements are required annually.
- Holding companies for investments into India and Africa
- Private equity and venture capital fund structures
- International trading companies routing through a treaty-friendly jurisdiction
- Family offices and wealth management structures
Key Facts
Step-by-Step Formation Process
Engage a Mauritius management company
A GBC must be administered by a licensed management company (MC) in Mauritius. The MC handles incorporation, compliance, and ongoing administration. Select an MC based on their experience with your target treaty network and investment structure.
Apply for a Global Business Licence from the FSC
Submit the application to the Financial Services Commission (FSC) along with a detailed business plan, KYC documents for all beneficial owners and directors, source-of-funds declarations, and the proposed constitutional documents. The FSC conducts a thorough review.
Incorporate the company with the Registrar of Companies
Once the FSC issues the Global Business Licence, the management company files the incorporation documents with the Registrar of Companies. The company is incorporated under the Mauritius Companies Act 2001.
Appoint at least two Mauritius-resident directors
The GBC must have at least two directors resident in Mauritius at all times. The management company typically provides nominee directors who meet this requirement, though appointing independent local directors strengthens substance.
Open a corporate bank account
Apply for a bank account with a Mauritius-based bank (SBM, MCB, AfrAsia, ABSA Mauritius) or an international bank with a Mauritius presence. The management company assists with the application. Account opening typically requires in-person or video verification of beneficial owners.
Register with the Mauritius Revenue Authority
Register the GBC for tax purposes with the MRA. The company must file annual tax returns and audited financial statements.
Required Documents
- Certified passport copies of all directors, shareholders, and beneficial owners
- Proof of residential address for all parties (utility bill or bank statement, not older than 3 months)
- Detailed business plan including proposed activities and target markets
- Source-of-funds and source-of-wealth declarations
- Bank reference letters for all beneficial owners
- Professional reference letters (lawyer or accountant)
- Constitutional documents (Constitution of the company)
- Board resolution of the parent company authorising the formation (if applicable)
Cost Overview
Tax Treatment
A GBC is taxed at the standard Mauritius corporate tax rate of 15%. However, foreign-source income qualifies for an 80% partial exemption, resulting in an effective tax rate of approximately 3%. To qualify, the company must be centrally managed and controlled in Mauritius, employ (directly or through its management company) a reasonable number of qualified persons, and incur a minimum annual expenditure in Mauritius proportionate to its activities. The company must demonstrate that it is not established to serve as a conduit for treaty benefits. There is no capital gains tax. Withholding tax on dividends paid by a GBC to non-residents is 0%. Audited financial statements are required annually.
Pros & Cons
- Effective tax rate of approximately 3% on foreign-source income through the 80% partial exemption
- Extensive double tax treaty network — particularly the India DTAA, which has historically made Mauritius the #1 FDI route into India
- OECD-compliant jurisdiction with a credible international reputation
- Full capital repatriation — no exchange controls
- Bilingual (English and French) professional services sector
- Time zone advantage (GMT+4) for bridging Asian and European business hours
- Stable political environment and well-established rule of law
- Requires genuine local substance — at least two resident directors, a registered office, and local management
- Management company fees add a meaningful annual cost layer
- The India DTAA has been renegotiated — capital gains exemption was removed in 2017 for investments made after April 2017
- OECD and EU scrutiny of Mauritius treaty structures has increased
- Small domestic market — Mauritius works as a structuring hub, not a consumer market play
- FSC licensing process is thorough and can be slow for complex structures
Other Structures in Mauritius
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Get StartedThis content is educational and does not constitute legal or tax advice. Always consult a qualified professional for your specific situation. Data last verified March 2026.