Investment Holding Company in Mauritius

Structure the holding of your international assets in one of the most advantageous jurisdictions in the world: optimised taxation, tax treaties and legal security.

Why Mauritius for your investment holding company?

Mauritius has established itself as one of the leading jurisdictions for international holding structures, particularly for investment into Africa and Asia. The combination of attractive taxation, an extensive network of tax treaties and a solid regulatory framework (based on the Companies Act 2001 and the Financial Services Act 2007) makes Mauritius a preferred choice for institutional investors, private equity funds and international entrepreneurs.

~3% GBC effective rate
0% Tax on capital gains
0% Withholding on outgoing dividends
40+ Tax treaties

Tax advantages of a Mauritian holding company

Tax advantage Detail
Taxation of foreign income (GBC)~3% effective (80% exemption via deemed FTC)
Tax on capital gains on disposal0% (no exit taxation)
Withholding tax — outgoing dividends0%
Withholding tax — outgoing interest0%
Withholding tax — outgoing royalties0%
Inheritance tax0%
Tax treaties45 DTAs in force (MRA, 2026) covering Africa, Asia, Europe
Exchange controlsNo restrictions on capital movements

Decisive advantage: the total absence of tax on capital gains allows shareholdings to be disposed of without taxation at the holding company level. Combined with the absence of withholding tax on distributions, this tax treatment ensures efficient capital flows between the levels of the structure.

Types of holding companies in Mauritius

Pure holding company (investment holding)

Holding of interests in subsidiary companies with no operating activity of its own. Receipt of dividends, interest and capital gains on disposal. The most common structure for centralising international shareholdings.

Mixed holding company (trading and holding)

Combination of holding interests with operating activities: trading, consulting, management services. Charging management fees to subsidiaries and centralising functions (treasury, IT, HR).

Real estate holding company

Holding of international real estate assets via subsidiary companies. Optimisation of taxation on rental income and capital gains on disposal through DTAs.

Intellectual property holding company

Holding and managing patents, trademarks, copyrights and licences. Receipt of royalties with 0% outgoing withholding tax from Mauritius.

Legal structure: GBC or AC for your holding company?

In the vast majority of cases, the GBC is recommended for holding companies because access to tax treaties is one of the main reasons for locating a holding company in Mauritius. The AC can be suitable for simple holding companies with no need for DTAs.

Criterion GBC Holding AC Holding
Access to DTAsYes — essential for reducing withholding taxNo
Tax Residence CertificateYes — necessary to apply treaty ratesNo
Taxation~3% effective0%
Substance required2 resident directors, local administrationRegistered agent only
AuditMandatory (licensed auditor)Reduced
Annual costUSD 4,000 – 8,000+USD 1,500 – 3,000+
RecommendationHolding companies with subsidiaries in DTA countriesSimple holding companies with no need for DTAs

Optimising withholding tax through DTAs

One of the main advantages of the GBC holding company is the reduction of withholding tax on dividends, interest and royalties from subsidiaries thanks to Mauritius's network of tax treaties. Without a treaty, source countries apply their domestic rates, often between 20% and 30%. DTAs significantly reduce these rates.

Source country Dividends (DTA rate) Interest (DTA rate) Royalties (DTA rate)
India5-15%7.5%15%
South Africa5-15%0-10%5%
China5%10%10%
Singapore0%0%5%
France5-15%0%0%
United Kingdom10-15%0%15%
Kenya5%10%10%
Madagascar10%10%5%

The rates shown are indicative and may vary depending on the specific conditions of each treaty (participation thresholds, limitation-of-benefits clauses). Some treaties have been amended by the OECD's Multilateral Convention (MLI). Consult a tax advisor for the rates applicable to your situation.

Financial flows of a Mauritian holding company

The Mauritian holding company optimises the group's financial flows through an efficient three-level scheme:

  1. Incoming flows: dividends from subsidiaries

    Subsidiaries distribute dividends to the holding company in Mauritius, benefiting from reduced withholding tax rates provided under tax treaties (5% to 15% depending on the country, versus 20-30% without a treaty).

  2. Taxation in Mauritius

    Foreign-source income is taxed at approximately 3% effective after application of the 80% exemption (deemed Foreign Tax Credit). Capital gains on disposal of shareholdings are not taxed (0%).

  3. Outgoing flows: distribution to shareholders

    The holding company distributes profits to its shareholders without withholding tax (0%) and without tax on capital gains in the event of disposal of the holding company's shares.

Mauritius as a platform to Africa

Mauritius has become the leading investment platform into Africa, channelling billions of dollars of investment onto the continent. The advantages for investment holding companies in Africa are numerous. The holding company can also be combined with Mauritian trusts for optimal wealth planning, or serve as a platform for investment funds in Mauritius:

  • Tax treaties with numerous African countries: South Africa, Botswana, Kenya, Madagascar, Mozambique, Namibia, Uganda, Rwanda, Senegal, Zambia, Zimbabwe, etc.
  • Bilateral Investment Treaties (BITs) offering protection against expropriation and access to international arbitration (ICSID, UNCITRAL)
  • Member of SADC and COMESA: preferential access to regional African markets
  • Favourable time zone (GMT+4): overlapping with Africa, Europe and Asia
  • Bilingual workforce (English and French), familiar with both French-speaking and English-speaking African markets

Group treasury

The Mauritian holding company can also serve as a treasury centre for the group, centralising financing functions:

  • Intragroup loans: the holding company grants loans to subsidiaries, receiving interest taxed at ~3% effective. DTAs reduce the withholding tax on interest in the subsidiary's country
  • Cash pooling: centralisation of the group's cash surpluses for optimised management
  • Acquisition financing: the holding company raises financing for the acquisition of new shareholdings
  • Currency management: multi-currency accounts (USD, EUR, GBP, ZAR) allowing exchange rate risk to be managed

Economic substance for holding companies

Substance requirements for a GBC holding company must be proportionate to its activity. The FSC assesses substance on a case-by-case basis:

  • Two resident directors in Mauritius at minimum, with relevant expertise in investment management
  • Board meetings held in Mauritius, with documentation of investment and divestment decisions
  • Local administration: accounting, records and correspondence managed from Mauritius
  • Operational bank account in Mauritius with genuine transactions
  • Local expenditure proportionate to income and assets managed

The management company provides the resident directors, administration and compliance support. To learn more, see our guide to registered office and substance.

Costs of a holding company in Mauritius

Item GBC Holding (USD/year) AC Holding (USD/year)
Management company and administration2,000 – 4,000800 – 1,500
FSC licence500 – 1,500250 – 500
Annual audit1,500 – 3,000500 – 1,000
Resident directorsIncluded or 500 – 1,500N/A
Registered office500 – 1,500300 – 800
Total per year4,000 – 8,000+1,500 – 3,000+

For a detailed budget forecast, see our guide to formation costs.

Points of caution

  • CFC rules: check that the holding company does not trigger Controlled Foreign Company (CFC) rules in the jurisdiction of residence of the ultimate shareholder. Several European countries apply CFC rules that can tax the holding company's income at the shareholder level
  • Principal Purpose Test (PPT): modern tax treaties (as amended by the MLI) include anti-abuse clauses. The holding company must have genuine substance and a commercial purpose beyond the tax advantage
  • Transfer pricing: intragroup transactions (management fees, loans, royalties) must comply with the arm's length principle. Mauritius has adopted OECD guidelines on transfer pricing
  • Evolution of treaties: some treaties are subject to renegotiation. Follow developments, particularly the treaties with India (renegotiated in 2016) and South Africa
  • BEPS and MLI: Mauritius has signed the OECD's Multilateral Convention (MLI), incorporating anti-BEPS measures that may alter the application of certain bilateral treaties

The information presented is provided for guidance only. Structuring an international holding company requires an in-depth tax and legal analysis taking into account all jurisdictions involved. Consult a qualified professional.

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Frequently Asked Questions

Why set up a holding company in Mauritius?

Mauritius offers an exceptional tax framework for holding companies: an effective rate of ~3% via the GBC subject to meeting substance conditions, 0% tax on capital gains on disposal, 0% withholding tax on outgoing dividends, access to 45 tax treaties in force (MRA, 2026), and free repatriation of capital. These advantages make Mauritius a leading jurisdiction for holding international assets.

What type of company should I choose for a holding company in Mauritius?

The GBC is recommended for holding companies wishing to access tax treaties and reduce withholding tax on incoming dividends. The AC is suitable for simple holding companies with no need for DTA access. For multi-fund structures, the PCC or the VCC may be considered.

What assets can a Mauritian holding company hold?

A GBC holding company can hold interests in foreign companies, investment portfolios (shares, bonds), international real estate, intellectual property, intragroup receivables and loans, as well as interests in investment funds.

How are dividends received by the holding company taxed?

Foreign-source dividends received by a GBC benefit from the 80% exemption, bringing the effective rate down to ~3%. In addition, tax treaties may reduce the withholding tax applied in the subsidiary's country. Dividends redistributed by the holding company are not subject to any withholding tax in Mauritius (0%).

Does the holding company need to employ staff in Mauritius?

If the holding company is structured as a GBC, it must demonstrate economic substance proportionate to its activities: at least 2 resident directors and a level of management activity in Mauritius. The management company can provide these services. For a purely asset-holding company, staffing requirements are generally limited.

What are the accounting obligations of a GBC holding company?

A GBC holding company must keep full accounting records in Mauritius, produce annual financial statements audited by a licensed auditor, and file its accounts with the FSC and the Registrar. It must also file an annual tax return with the Mauritius Revenue Authority (MRA).

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