Two structures, two philosophies
The choice between a Global Business Company (GBC) and an Authorised Company (AC) is the most structuring decision when setting up a company in Mauritius. Both vehicles are governed by the Financial Services Act 2007 and supervised by the FSC, yet they follow fundamentally different logics.
The GBC is a company tax resident in Mauritius, taxed at the standard rate of 15%, with an effective rate that can fall to around 3% on certain foreign income thanks to the 80% partial exemption, subject to meeting substance conditions, and it benefits from access to the 45 tax treaties in force (MRA, 2026). The AC is a non-tax-resident structure, taxed only on its Mauritius-source income (subject to its filing obligations with the MRA) but without access to tax treaties. The right choice depends on your business strategy, your target markets and your tax objectives.
The central question
Do you need access to Mauritius's double taxation avoidance treaties? If yes, the GBC is your only option. If not, the AC offers you a total exemption at lower cost.
Detailed comparison
Taxation
| Tax criterion | GBC | AC |
|---|---|---|
| Nominal rate | 15% | 15% (not applicable in practice) |
| Foreign income exemption | 80% (deemed FTC) | 100% |
| Effective rate | ~3% | 0% |
| Access to DTAs (40+) | Yes | No |
| Tax Residence Certificate (TRC) | Yes | No |
| Capital gains tax | 0% | 0% |
| Dividend withholding tax | 0% | 0% |
| Interest withholding tax | 0% | 0% |
Key point: the 3-percentage-point difference between the GBC (3%) and the AC (0%) may seem modest, but the GBC's access to tax treaties can represent far greater savings in terms of reduced withholding tax on incoming flows. For example, a dividend of USD 100,000 from India could be subject to a 20% withholding tax without a treaty (USD 20,000) versus 5% under the Mauritius–India treaty (USD 5,000), a saving of USD 15,000 that largely offsets the USD 3,000 of effective tax paid in Mauritius.
Substance and governance
| Requirement | GBC | AC |
|---|---|---|
| Resident directors in Mauritius | Minimum 2 | Not required |
| Registered agent | Yes (management company) | Yes (management company) |
| Registered office in Mauritius | Mandatory (physical premises) | Correspondence address |
| Accounting in Mauritius | Mandatory | Adequate records |
| Annual audit | Mandatory (licensed auditor) | Lighter |
| Staff in Mauritius | Proportional to activity | Not required |
| Board meetings in Mauritius | Recommended / required by the FSC | Flexible (any location) |
Costs and timelines
| Item | GBC (USD) | AC (USD) | Difference |
|---|---|---|---|
| Incorporation (one-off) | 1,500 – 3,000 | 800 – 1,500 | ~-50% |
| Total annual budget | 3,000 – 6,000+ | 1,500 – 3,000+ | ~-50% |
| Formation time | 2 – 4 weeks | 1 – 2 weeks | ~-50% |
| Administrative complexity | High | Moderate | — |
When to choose the GBC
The GBC is the optimal choice in the following situations:
Investments in Africa or Asia
The GBC gives access to DTAs with India, South Africa, Kenya, China, Singapore and other countries, reducing dividend withholding tax from 20-30% to 5-15%.
Investment holding
For a holding company owning stakes in treaty-signatory countries, the GBC optimises the upstreaming of dividends and capital gains on disposal (0% in Mauritius).
Tax residence certificate
If your counterparties or banks require a Tax Residency Certificate (TRC) to apply treaty rates, only the GBC can obtain one from the MRA.
Institutional credibility
The GBC, a resident and regulated company with economic substance, projects an image of solidity for institutional partners, banks and investors.
When to choose the AC
Activities with no link to DTAs
If your transactions involve countries not covered by Mauritius's treaties, or if the treaties are not relevant to your income, the AC offers 0% tax at lower cost.
Limited budget
The AC halves formation and maintenance costs compared with the GBC (USD 1,500-3,000/year vs USD 3,000-6,000/year), with total tax exemption.
International trading
Trading companies buying and selling between third countries, with no passive income flows subject to withholding tax, take full advantage of the AC's exemption.
E-commerce and digital services
Digital service businesses invoicing clients worldwide can centralise their revenue without taxation (except for Mauritius-based clients).
Decision tree
To help you decide, here are the key questions to ask yourself, in order:
-
Do you need access to tax treaties?
Yes: choose the GBC. No: move to the next question.
-
Do your counterparties require a tax residence certificate?
Yes: choose the GBC. No: move to the next question.
-
Do you plan to carry out activities in Mauritius?
Yes: choose the GBC (the AC cannot carry out local activities). No: move to the next question.
-
Is budget a decisive factor?
Yes: choose the AC (USD 1,500-3,000/year vs USD 3,000-6,000/year). No: move to the next question.
-
Do you want to minimise substance and audit obligations?
Yes: choose the AC. No: choose the GBC for better institutional credibility.
Case studies
Case 1: Investment holding in Africa
Profile: an investment fund holding stakes in Kenya, South Africa and Mozambique.
Recommendation: GBC. Access to tax treaties reduces withholding tax on dividends upstreamed from the African subsidiaries. The tax residence certificate is essential to claim treaty rates. The absence of capital gains tax in Mauritius (0%) optimises the disposal of the stakes.
Case 2: Commodity trading company
Profile: an independent trader buying commodities in Latin America and reselling them in Asia.
Recommendation: AC. Trading transactions do not generate passive income subject to withholding tax. The 0% exemption and reduced costs are optimal. The fast formation time (1-2 weeks) is an added advantage.
Case 3: IT consulting company
Profile: a technology consultant invoicing clients in Europe and Asia.
Recommendation: AC if the clients are in countries with no relevant DTA for the services, or if the volume of business does not justify the costs of a GBC. GBC if the consultant wants a stronger institutional image for large clients or anticipates growth that requires tax treaties.
Case 4: International e-commerce platform
Profile: a SaaS start-up with clients in 20 countries.
Recommendation: AC to start with controlled costs and total exemption, with the possibility of converting to a GBC if growth requires access to tax treaties or greater institutional credibility.
Possibility of conversion
It is possible to convert an AC into a GBC (and vice versa) if your needs evolve. This flexibility allows you to start with an AC and migrate to a GBC when your activity justifies it, without having to create a new entity.
Conversion requires:
- Meeting the GBC substance requirements (appointment of 2 resident directors, local administration)
- Filing a new licence application with the FSC
- Updating the constitutive documents
- A timeframe of 4 to 8 weeks for the full procedure
- Conversion fees equivalent to the incorporation fees of a GBC
Advice: if you are hesitating between the two structures and have no immediate need for DTA access, starting with an AC is often the most prudent strategy. You can always convert to a GBC later. On the other hand, if you know from the outset that you will need tax treaties, set up a GBC directly to avoid the costs and delays of conversion.
Summary of recommendations
| Situation | Recommendation | Main reason |
|---|---|---|
| Investment in Africa / Asia | GBC | Access to DTAs |
| Shareholding holding company | GBC | Withholding tax optimisation |
| International trading | AC | 0% tax, reduced costs |
| International consulting | AC or GBC | Depending on volume and desired image |
| E-commerce / SaaS | AC | Total exemption, flexibility |
| Fintech / financial services | GBC | Credibility, specific licences |
| Fund management | GBC | Access to DTAs, regulated framework |
| Simple wealth-holding structure | AC | Minimal costs |
| Group treasury | GBC | DTAs on interest, substance |
| Intellectual property | GBC | DTAs on royalties |
Also use our interactive GBC vs AC comparator to get a personalised recommendation based on your specific criteria.
The information presented is provided for guidance only and does not constitute legal or tax advice. The choice of legal structure should be the subject of a personalised analysis by a qualified professional, taking into account your tax situation in all relevant jurisdictions.