What is a Global Business Company?
The Global Business Company (GBC) is the flagship legal vehicle of the Mauritian financial centre for international operations. Governed by the Financial Services Act 2007 and supervised by the Financial Services Commission (FSC), the GBC holds a Global Business Licence which grants it a privileged tax status and access to Mauritius's network of double taxation agreements.
Since the 2019 reform, the GBC has replaced the former GBC1 and GBC2 categories, unifying the regulatory framework and strengthening economic substance requirements. This evolution has consolidated Mauritius's reputation as a jurisdiction compliant with international OECD standards and the Global Forum on transparency and exchange of information for tax purposes. The GBC is now a Mauritian tax resident company, subject to corporate tax but benefiting from a partial exemption regime on foreign-source income.
The GBC in brief
Tax resident in Mauritius, the GBC benefits, subject to substance conditions, from an effective tax rate of around 3% on specified foreign-source income, provides access to the 45 double taxation agreements in force (MRA, 2026), and is the vehicle of choice for investment into Africa and Asia.
Key advantages of the GBC
Optimised taxation
The GBC is subject to corporate tax in Mauritius at the nominal rate of 15%. However, thanks to the deemed Foreign Tax Credit (FTC) mechanism, it benefits from an 80% exemption on foreign-source income. The effective tax rate thus works out at around 3%. This mechanism applies automatically once the substance conditions are met: for every USD 100 of foreign income, the theoretical tax is USD 15, of which USD 12 is covered by the deemed tax credit, leaving a net tax charge of USD 3.
| Tax item | Rate / Detail |
|---|---|
| Nominal corporate tax | 15% |
| FTC exemption on foreign income | 80% |
| Effective tax rate | ~3% |
| Tax on capital gains | 0% |
| Withholding tax — dividends | 0% |
| Withholding tax — interest | 0% |
| Withholding tax — royalties | 0% |
| Inheritance tax | 0% |
Access to tax treaties
One of the major strengths of the GBC is its access to the network of 45 double taxation agreements (DTAs) in force (MRA, 2026) signed by Mauritius. This network covers jurisdictions that are strategic for investors:
- Africa: South Africa, Botswana, Kenya, Madagascar, Mozambique, Uganda, Rwanda, Senegal, Zambia, Zimbabwe
- Asia: India, China, Singapore, Malaysia, Thailand, Nepal, Sri Lanka, Bangladesh
- Europe: France, United Kingdom, Germany, Belgium, Luxembourg, Cyprus, Guernsey, Jersey
- Middle East: United Arab Emirates, Oman, Kuwait, Qatar
These double taxation agreements reduce or eliminate double taxation on cross-border income (dividends, interest, royalties, capital gains), making Mauritius a preferred investment platform into Africa and Asia. To benefit from treaty rates, the GBC must obtain a Tax Residency Certificate (TRC) from the Mauritius Revenue Authority (MRA).
Key point: only the GBC can obtain a Tax Residency Certificate (TRC) in Mauritius. The Authorised Company cannot. If you need to apply the reduced rates provided by tax treaties, the GBC is the only option.
Operational flexibility
No minimum capital
No minimum share capital is required by law. However, capital must be sufficient to demonstrate the viability of the activity.
100% foreign
Fully foreign shareholding is permitted. No requirement for a local partner or Mauritian participation.
Multi-currency
Bank accounts in USD, EUR, GBP, ZAR and other currencies. Free repatriation of profits and capital without restriction.
Versatile
Adaptable structure: trading company, holding, consulting, commerce, intellectual property, group treasury.
Substance conditions and requirements
Since the 2019 reform, the GBC must demonstrate genuine economic substance in Mauritius. These economic substance requirements, in line with OECD recommendations on harmful tax practices (BEPS Action 5), are designed to ensure the company is not a mere letterbox company and that management and decision-making activities are genuinely carried out from Mauritius.
Minimum substance requirements
| Requirement | Detail |
|---|---|
| Resident directors | Minimum 2 directors who are tax resident in Mauritius |
| Registered office | Physical address in Mauritius (main office of the management company) |
| Administration | Accounting, registers and statutory documents kept in Mauritius |
| Board meetings | Held in Mauritius or with majority participation from Mauritius |
| Staff | Qualified employees in Mauritius proportionate to the activity |
| Local expenditure | Level of expenditure proportionate to activities and income |
| Local bank account | Operating account with a Mauritian bank |
The management company plays a central role in meeting these obligations by providing resident directors, the registered office, accounting administration and corporate secretarial services. The FSC assesses substance on a proportionate basis: a pure holding company will face different requirements than an active trading company or a fund manager.
Warning: a GBC whose substance is judged insufficient by the FSC risks corrective measures, suspension or revocation of its licence, resulting in the loss of its privileged tax status and the inability to use tax treaties.
GBC formation process
Setting up a GBC follows a rigorous multi-step process. The management company, licensed by the FSC, coordinates the entire process.
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Preliminary study and structuring
Analysis of your project, identification of the optimal structure, preparation of the business plan and determination of the tax strategy. Choice of a management company licensed by the FSC.
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Due diligence and document collection
KYC verification: certified passports, proof of address, bank references, directors' CVs, business plan, proof of source of funds and identification of ultimate beneficial owners (UBO).
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Incorporation with the Registrar
Filing of the constitutive documents (Constitution, incorporation form) with the Registrar of Companies. Obtaining the Business Registration Number (BRN) and certificate of incorporation.
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FSC licence application
Submission of the Global Business Licence application to the FSC together with the business plan, due diligence results and evidence of substance. The FSC may request additional information.
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Operationalisation
Opening bank accounts, setting up the registered office, appointing auditors, obtaining the TAN and TRC, and starting operational activities.
Indicative timeline
| Phase | Estimated duration |
|---|---|
| Document collection and KYC | 1 to 2 weeks |
| Incorporation (Registrar) | 2 to 5 business days |
| FSC licence | 1 to 3 weeks |
| Bank account opening | 2 to 4 weeks |
| Total (excluding bank account) | 2 to 4 weeks |
Formation and maintenance costs
| Expense item | Indicative amount (USD) |
|---|---|
| Incorporation fees (one-off) | 1,500 – 3,000 |
| Annual FSC licence | 500 – 1,500 |
| Management company (annual) | 1,500 – 3,500 |
| Resident directors (annual) | Included or 500 – 1,500 |
| Accounting and bookkeeping | 1,000 – 2,500 |
| Annual audit | 1,000 – 3,000 |
| Registered office | 500 – 1,500 |
| Corporate secretarial services | Included or 300 – 800 |
| Total annual budget | 3,000 – 6,000+ |
These amounts are indicative and vary depending on the management company chosen, the complexity of the structure and the volume of activity. More complex structures (multi-jurisdictional, regulated activities) incur higher costs. See our detailed cost guide for a complete budget forecast.
Annual compliance obligations
A GBC must comply with strict compliance obligations to maintain its FSC licence. Failure to comply with these obligations can lead to penalties, suspension or revocation of the licence.
- Audited financial statements: filed with the FSC and the Registrar within 6 months of the financial year end, audited by an auditor licensed in Mauritius
- Tax return: filing of the corporate tax return with the Mauritius Revenue Authority (MRA) within 6 months of the end of the financial year
- Licence renewal: annual payment of FSC licence fees
- Annual Return: annual report filed with the Registrar of Companies
- Register of beneficial owners: regularly updated with the FSC, in accordance with anti-money-laundering requirements
- AML/CFT compliance: compliance with obligations to combat money laundering and the financing of terrorism (FIAMLA 2002)
- Common Reporting Standard (CRS): automatic exchange of tax information in accordance with OECD standards with more than 100 jurisdictions
Common GBC activities
The GBC is a versatile vehicle that can carry out a wide range of activities. Certain regulated activities require specific licences from the FSC or the Bank of Mauritius.
Investment holding
Holding of shareholdings in foreign companies, optimising the upstreaming of dividends through tax treaties.
International trading
Import-export, commodity trading, commercial intermediation between Africa, Asia and the rest of the world.
Financial services
Fund management, brokerage, advisory services (under a specific FSC licence), captive insurance, fintech.
Intellectual property
Holding and management of patents, trademarks and copyrights. Collection of royalties at reduced rates through DTAs.
Consulting and IT
Management consulting, software development, SaaS, digital platforms, engineering.
Group treasury
Centralisation of treasury functions, intragroup loans, cash pooling, foreign exchange risk management.
GBC and investment in Africa
The Mauritian GBC has become an essential vehicle for investment into Africa. Thanks to tax treaties with numerous African countries, Mauritius offers a unique investment platform enabling investors to:
- Reduce withholding tax on dividends from African subsidiaries (treaty rates of 5% to 15% depending on the country, compared with 20% to 30% without a treaty)
- Secure investments through bilateral investment treaties (BITs) offering protection against expropriation and access to international arbitration
- Centralise the management of African shareholdings in a stable and regulated environment
- Benefit from an English-speaking legal framework compatible with most African jurisdictions
Mauritius is a member of the SADC (Southern African Development Community) and COMESA (Common Market for Eastern and Southern Africa), strengthening its position as a gateway to the African continent. Discover all the tax advantages of Mauritius for international investors. To learn more about structuring a holding company, see our guide to the Mauritian holding company.
Points to watch
Before setting up a GBC, it is important to consider certain factors to ensure the compliance and sustainability of your structure:
- Genuine and ongoing substance: substance requirements must be met continuously, not only at the time of formation. The FSC carries out regular checks
- Tax residence: the GBC is tax resident in Mauritius, which may have implications in your country of residence (CFC rules, reporting obligations)
- Recurring costs: maintaining a GBC involves significant annual fees (USD 3,000 to 6,000+) which should be factored into your business plan
- Regulatory developments: Mauritius regularly adapts its framework to international standards (OECD, EU, FATF). The MLI Convention may modify the application of certain tax treaties
- Compatibility with your country of residence: check the CFC (Controlled Foreign Company) rules and reporting obligations in your home jurisdiction before setting up the structure
- Principal Purpose Test (PPT): modern tax treaties include anti-abuse clauses. The GBC must have genuine substance and a commercial purpose beyond the tax advantage
The information presented on this page is provided for indicative purposes only and does not constitute personalised legal or tax advice. Mauritian and international legislation is subject to regular change. Consult a qualified professional before making any investment decision.