What is this diagnostic for?
This diagnostic helps you map out, in a few questions, the main families of options available in Mauritius for structuring a business or organising a relocation: a domestic company, an international-oriented company (GBC or Authorised Company), a trust or foundation, and the various residence permits. It does not replace a meeting with an advisor: it is there to prepare that discussion by identifying the avenues relevant to your situation.
What this diagnostic does not do
This diagnostic does not calculate any tax saving and does not indicate any future tax amount. It does not constitute personalised tax, legal or financial advice. Every situation depends on factors specific to the director, the activity and the country of residence, which only an individual analysis can properly examine.
Why a Mauritian structure should not be chosen on a rate alone
The tax rate advertised by a Mauritian structure is only one factor among others. Several points actually determine the effective taxation of a director or a company:
- The director's tax residence. In Mauritius, it is assessed according to a physical presence test (183 days in the year, or 270 cumulative days over three years) or a domicile test. Remaining a tax resident of one's home country while directing a Mauritian company does not automatically change personal taxation in that country.
- The place of effective management. A company whose decisions are made from France, Belgium, Switzerland or Luxembourg may be regarded by that country's tax authorities as having its real tax residence there, regardless of the place of incorporation.
- The anti-abuse rules of the country of residence. France has specific mechanisms targeting lightly taxed foreign structures controlled by French residents: Article 209 B of the General Tax Code for companies, Article 123 bis for individuals. Belgium, Switzerland and Luxembourg also have anti-abuse rules or place-of-effective-management criteria that can lead to the income of a Mauritian structure being taxed locally.
- Substance. The partial exemption applicable to certain foreign income of a GBC requires meeting substance conditions in Mauritius: income-generating activities effectively carried out on site, qualified staff, and expenditure proportionate to the activity. A structure without genuine substance is not entitled to it.
The main families of options
- The Global Business Company (GBC), a Mauritian tax resident, which gives access to double taxation treaties;
- the Authorised Company (AC), a non-tax-resident, taxed only on its Mauritian-source income;
- a detailed comparison to choose between the two: GBC or AC;
- residence permits allowing you to settle in Mauritius, notably the Occupation Permit Investor and the self-employed permit;
- the trust or foundation for asset-holding and succession matters;
- and, to put it all in context, Mauritian taxation applicable to both companies and individuals.
Sunibel Corporate Services, a management company licensed by the Financial Services Commission and a member of the Probus Pleion group, supports the analysis of these options on a case-by-case basis. No outcome can be guaranteed in advance: each case depends on the personal and professional situation of the project holder.
What the diagnostic covers
The diagnostic asks a short series of questions and then produces an orientation based on your answers. Introduction shown to the user: "This diagnostic helps you understand, in a few minutes, which structures and statuses are usually relevant to your situation. It does not calculate any tax saving and does not replace personalised advice: it points you in a direction and flags the points to check with a professional."
Questions asked
- In which country are you currently tax resident? Your current tax residence determines which anti-abuse rules may apply to a structure in Mauritius. Options: France, Belgium, Switzerland, Luxembourg, United Arab Emirates, Africa, Other country.
- Are you considering relocating personally to Mauritius? A relocation changes the applicable personal taxation and the residence statuses accessible. Options: Yes, it is planned; It is being considered, not yet decided; No, I will remain resident elsewhere.
- What is the main nature of your activity? It points towards one type of structure rather than another. Options: Services; Digital or remote activity; Holding of shareholdings (holding); Trading; Fund or asset management; Real estate.
- Where are your clients or markets mainly located? The location of markets influences access to tax treaties and the relevant type of licence. Options: In Mauritius; In Africa; In Europe; In Asia; Spread worldwide.
- Do you already have a structure or a residence abroad? An existing structure, notably in the United Arab Emirates, may change the points to watch. Options: No existing structure; A company in my country of residence; A structure or residence in the United Arab Emirates.
- What is your main objective? It helps direct you towards the options best suited to your priority. Options: Create or structure a company; Obtain resident status in Mauritius; Organise the holding and transmission of my wealth; I do not yet know precisely.
Result: options to consider
Based on your answers, here are the options usually relevant to consider, together with the associated points to watch. This result is a general orientation, not personalised advice.
| Option | Description | Conditions |
|---|---|---|
| Mauritian domestic company | An ordinary Mauritius-law company, referred to as a domestic company, is suitable when the activity is carried out mainly in Mauritius, for example in real estate or local services. As a tax resident, it is subject to corporate tax at the standard rate and does not benefit from the regimes reserved for internationally oriented companies. | Taxed at the standard corporate tax rate of 15%; suited to an activity generating income in Mauritius; local incorporation and registration, without a specific FSC licence; no access to the partial exemption regimes reserved for the Global Business Licence. |
| Global Business Licence (GBC) | The Global Business Licence is issued by the Financial Services Commission for internationally oriented companies, notably holding companies, trading or fund management. As a Mauritian tax resident, it gives access to the double taxation treaties in force, subject to substance conditions verified by the authorities. | Licence issued by the FSC; company is tax resident in Mauritius; access to the 45 double taxation treaties in force (MRA, 2026); possible 80% partial exemption on certain foreign income, subject to substance conditions; mandatory administration by a management company licensed by the FSC. |
| Authorised Company (AC) | The Authorised Company suits an activity carried out outside Mauritius, with no local clientele, where management and control remain exercised abroad. As a non-tax-resident, it is taxed only on its Mauritian-source income, but has no access to the tax treaties signed by Mauritius. | Non-tax-resident; management and control exercised outside Mauritius; taxed only on Mauritian-source income; return and financial summary to be filed with the MRA within 6 months; mandatory registered agent: a management company licensed by the FSC. |
| Trust or foundation | A Mauritius-law trust or foundation allows the holding of assets or a wealth transmission to be structured, particularly in the presence of a holding company. Mauritius levies neither capital gains tax nor inheritance duties, making it a recognised framework for organising family or business wealth over the long term. | No capital gains tax or inheritance duties in Mauritius; suited to holding assets or wealth transmission; requires a trustee or a licensed professional advisor; to be coordinated with the tax and inheritance rules of the country of residence. |
| Self-Employed permit | The Self-Employed permit allows a self-employed individual to carry out a service or digital activity in Mauritius. It requires an initial investment and growing income, verified from the third year, making it an option for a personal relocation linked to a service-based or digital activity. | Required initial investment: USD 50,000; expected income of at least MUR 2 million from year 3, MUR 3 million in year 5; reserved for service activities or independent professions; assumes an effective relocation to Mauritius. |
| Occupation Permit Investor | The Occupation Permit Investor is aimed at an investor creating or taking over a company in Mauritius, with a growing turnover requirement. It is the most general option for a relocation linked to an economic activity, whatever the sector, provided a sufficient investment is made in the company. | Required initial investment: USD 100,000; turnover of at least MUR 5 million per year from year 3; renewal in year 5 conditional on MUR 8 million turnover; assumes effective management of a company in Mauritius. |
| Premium Visa | The Premium Visa allows an extended, renewable stay in Mauritius, without creating a local company or automatically transferring tax residence. It suits a digital activity carried out for clients located outside Mauritius, but strictly prohibits any paid activity on the Mauritian market. | Valid for up to one year, renewable; prohibition on working or being paid on the Mauritian market; does not in itself constitute Mauritian tax residence; suited to a digital activity carried out for clients located abroad. |
| Residence via real estate | Acquiring an eligible property (PDS, IRS, RES, Smart City or G+2) gives access to resident status in Mauritius, without an obligation to create or manage a company. This is a relevant option when the main objective is resident status rather than developing an economic activity. | Minimum real estate investment of USD 375,000; eligible schemes: PDS, IRS, RES, Smart City or G+2; resident status tied to ownership of the property; does not necessarily involve creating a company in Mauritius. |
Points to watch
- Anti-avoidance rules in the home country. If you remain tax resident in your current country, anti-abuse rules may apply to a lightly taxed foreign structure: in France, Article 209 B and Article 123 bis of the General Tax Code; Belgium, Switzerland and Luxembourg have comparable mechanisms. These rules can lead to profits or income being taxed in your country of residence.
- Place of management. A company may be considered tax resident in your country of residence if its effective management is exercised there, regardless of its place of incorporation: strategic decisions and day-to-day management must genuinely be carried out in Mauritius, and be capable of being documented as such.
- GBC substance. The 80% partial exemption on certain foreign income of a GBC is only secured if the substance conditions are met: income-generating activities effectively carried out in Mauritius, qualified staff and expenditure proportionate to the declared activity.
- Personal tax in Mauritius. In the case of tax residence in Mauritius (183 days, 270 days over 3 years, or domicile), your income is taxed according to the progressive scale in force since 1 July 2026: 0% up to MUR 500,000, 10% up to MUR 1,000,000, 20% up to MUR 12,000,000, 35% above that. Your foreign income is taxed upon repatriation to Mauritius.
- Leaving the UAE. Leaving the United Arab Emirates, where individuals are not subject to income tax, to become tax resident in Mauritius makes you taxable under the Mauritian progressive scale: this change of residence deserves to be anticipated before any transfer.
- Premium Visa — no local work. The Premium Visa strictly prohibits carrying out a paid activity on the Mauritian market: it suits an activity carried out for clients located abroad, not a local commercial establishment.
- Regulated activity. Trading or fund management activities may fall under a licence regulated by the Financial Services Commission, with specific substance and governance requirements to be checked on a case-by-case basis.
Disclaimer: this diagnostic provides a general orientation based on the information you have indicated; it constitutes neither tax advice nor personalised legal advice, and guarantees no outcome. It does not give any numerical estimate of tax saving. Only an individual analysis with a qualified professional can validate the structure best suited to your situation.
This diagnostic helps you understand, in a few minutes, which structures and statuses are typically relevant to your situation. It does not calculate any tax savings and does not replace personalised advice: it provides guidance and flags points to examine with a professional.
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