Global Business Licence
As per the Financial Services Act 2007, a Global Business licence is granted by the FSC to a resident company that conducts its core income generating activities outside of Mauritius. A GBC may be locally incorporated or may be registered as a branch of a foreign company.
A GBL company is resident for tax purposes in Mauritius and benefits from the network of Double Taxation Avoidance Agreements that Mauritius has ratified with numerous countries around the world.
As from 1st January 2019, the 80% deemed foreign tax credit (DFTC) that was applicable to Global Business Licence 1 (GBC1) will be abolished.
The DFTC will be replaced by a new Partial Exemption Regime, which will be based of 80% of the relevant income as follows:
• Foreign-source dividends derived by a company;
• Interest derived from overseas by a company other than a bank;
• Profit attributable to a permanent establishment of a resident company in a foreign country;
• Foreign-source income derived by a collective investment scheme (CIS), closed-end fund, CIS manager, CIS administrator, investment adviser or asset manager, licensed or approved by the Financial Services Commission; and
•Income derived from overseas by companies engaged in ship and aircraft leasing
Authorised Company
An Authorised Company (AC) is not resident in Mauritius for tax purposes and is thus exempt from all taxes and does not benefit from the Double Taxation Avoidance Agreement network.
An AC needs to demonstrate that its place of effective management (“POEM”) is outside of Mauritius and requires to submit a tax return even if it will not have a tax liability.
An AC is often used for activities where treaty benefits are not required such as invoicing, marketing and international trading.
