Authorised Company (AC)

A Mauritian company that is not tax resident, reserved for activities conducted exclusively outside Mauritius and taxed only on its Mauritian-source income.

Definition

The Authorised Company (AC) is a company incorporated in Mauritius but not tax resident there: its central management and control must be located outside Mauritius. This qualification distinguishes it from the Global Business Company (GBC), which is tax resident in Mauritius. This non-resident status governs the entire regime applicable to the AC, both in tax terms and in terms of filing obligations.

Framework in Mauritius

The AC is regulated by the Financial Services Commission (FSC), the regulator of non-bank financial services in Mauritius, which issues the licence required for its incorporation. Being non-tax resident, it is taxed only on its Mauritian-source income; foreign-source income is not subject to Mauritian tax. In return for this status, the AC has no access to the Mauritian network of double taxation treaties, unlike the GBC. Every AC must be administered by a registered agent, which must be a management company licensed by the FSC; this entity acts as the interface with the regulator and monitors filing obligations with the Mauritius Revenue Authority (MRA), including an income tax return and a financial summary.

In practice

The AC suits structures whose decision-making centre and activities are located outside Mauritius, and for which access to tax treaties is not a decisive factor. The choice between an AC and a GBC depends on the specific needs of each case — access or not to tax treaties, the level of substance achievable, the nature of the income — and deserves case-by-case review with the management company. One key point of caution: non-tax-resident status requires that central management and control actually be exercised outside Mauritius; any effective decision taken from within Mauritius could call this qualification into question. Filing obligations to the MRA apply regardless of the company's activity, and must be followed up with the registered agent throughout the life of the structure.

Related terms

The Authorised Company differs from the Global Business Company (GBC), which is tax resident and, subject to substance requirements, has access to double taxation treaties. Its incorporation and ongoing administration are handled by a management company licensed by the Financial Services Commission (FSC), the regulator common to both structures.

Related terms

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