International Expansion: Mauritius Overview

Mauritius is an island off the east coast of Africa and is the business and financial hub of Africa providing numerous advantages for setting up your company or preserving your wealth.

Mauritius is an island off the east coast of Africa and is the business and financial hub of Africa providing numerous advantages for setting up your company or preserving your wealth.

Amongst other things Mauritius has:
    • A favorable time zone.
    • Very attractive fiscal policies.
    • Many active double taxation agreements.
    • No exchange controls to limit the flow of money.
    • A very efficient banking system.
    • Reliable and modern infrastructure as well as professional staff and service providers to assist your company.
    • Tax rates ranging from 3% to 15%.

Besides all the advantages of doing business in Mauritius, it is a subtropical climate with good weather all year round providing for a five-star holiday destination.

Your research into the region noted that the main types of companies to be incorporated by foreigners in Mauritius is referred to as either a:

    • Global Business License (GBL)
    • An Authorized Company.

Other companies which may be established include Domestic Companies, Freeport Companies, and Limited Partnerships. Mauritius is also well known for a jurisdiction in which you can preserve your wealth and this is mainly achieved through the setting up of an offshore Trust.

You are interested in using Mauritius to preserve your international wealth for future generations, however, you know that making use of business structures may be advantageous to you at some stage.

  Global Business License (GBL) Authorized Company (AC) Domestic Company
Ownership 100% foreign, natural or legal 100% Foreign, natural or legal Residents or non-resident shareholders
Shareholders Min 1 / nominee shareholders can be used Min 1 / nominee shareholders can be used Min 1
Directors Min 2 Local resident directors No local directors Min 1 Local resident director
Board meetings Chaired from Mauritius Can be held anywhere Chaired from Mauritius
Company secretary Yes, management company Optional, has to have a registered agent Yes, must be a resident of Mauritius
Office space Required as part of Economic Substance Requirements Yes Yes
Economic Substance requirement required / management from Mauritius Yes – treaty benefits available No – no treaty benefit available Yes – treaty benefits available
Business activities No restrictions, in line with business plan company must make an investment or provide a product or a service outside Mauritius Same as for GCL. Restrictions include: banking, financial and fiduciary services and trusteeship business. No limitations. Except if the majority shareholder is non-resident.
Audit Yes, due 6 month after year end No, only summary report Yes if turnover is > MUR50million
Visas Dependent on minimum investment through the occupancy permit. No Must be a Mauritian citizen
Capital requirements No minimum No minimum No minimum
Privacy/Secrecy/public access Confidential Confidential Available to the public
Exchange controls No No No
KYC requirements On all registered, beneficial owners, bank signatories, directors On all registered, beneficial owners, bank signatories, directors On all registered, beneficial owners, bank signatories, directors
Taxation 15% 80% tax credit available resulting in the effective tax rate of 3% 0% 15%
Other taxes No Capital gains tax, Inheritance tax, WHT or tax on bank interest None No Capital gains tax, Inheritance tax, WHT or tax on bank interest

Global Business License

The main aim of this type of company is to make investments or to generate income from outside Mauritius. It may undertake any form of business provided that it is stipulated in its business plan.

Company type GBL
Shareholders and liability     Natural or legal, in proportion to shareholding
Disclosure No, except by court order
Confidentiality Confidential
Accounting and auditing Unaudited financial summary to be submitted 6 moths after year end
Tax resident Yes
Taxation Corporate tax capped at 15% The tax credit may apply reducing tax to 3% (subject to meeting certain criteria) No capital gains tax No withholding taxes on royalties or interest
Legislation Civil and Common law
Currency Mauritian rupee
Capital and profit repatriation No restriction
Local Sponsor requirement No
Directors Two resident directors required
Foreign ownership Yes
Residence Visas Based on occupancy permit requirements
License restrictions No
Specific requirements Have an annual minimum level of expenditure in Mauritian Rupee in line with its revenue generation (At least USD 12 000 per annum) To employ directly or indirectly a reasonable amount of suitably qualified employees to carry out the core income generation activities (i.e. 1 employee for turnover less than 100m USD)
Specific requirements – IP Requires you to prove that appropriate amount has been spent on R&D to meet the substance requirements
  • At some stage, your expansion will require a Mauritian company for which the qualifying criteria (at least one) for registering a GBL company includes:
    • Must have office premises in Mauritius;
    • Employ on full-time basis at least one person to deal with administration (this may include resident directors appointed by a management company);
    • MOI to include a clause to indicate that all dispute resolutions be dealt with by arbitration in Mauritius;
    • To holds assets within 12 months of incorporation of at least USD 100 000;
    • Shares to be listed on the stock exchange ;
  • Have annual expenditure in Mauritius comparable to any local business.

An Authorized Company may trade in any activity excluding banking, financial and fiduciary services and trusteeship busines. This type of company is a non-resident (not a tax resident) in Mauritius and does not require local directors. It may only deal with non-residents and in currencies other than the Mauritian Rupee.

Company type  
Shareholders and liability   Natural or legal, in proportion to shareholding
Disclosure No, except by court order
Confidentiality Confidential
Accounting and auditing Yes, audit required 6 months after year-end
Tax resident Yes
Taxation 0% tax in Mauritius. Tax is subject to other offshore jurisdictions.
Legislation Civil and common law
Currency USD or other
Capital and profit repatriation No restrictions
Local Sponsor requirement No
Directors No resident directors
Foreign ownership Yes
Residence Visas No
License restrictions Yes, cannot engage in any banking, financial and fiduciary services, and trustee business


A trust is a legal agreement entered into by the “Settlor” whereby he appoints “Trustees” to manage and look after all trust assets on behalf of “beneficiaries”.

    • Settlor – The person setting up the trust and from which the initial trust assets will be transferred to the trustees
    • Trustees – The custodians of the trust assets. Trustees are required to be independent. Trustees may therefore not also be a beneficiary
    • Beneficiaries – recipients or benefactors of trust assets.

Although trust arrangements may include numerous variations the most prevalent of these are whether a trust is a testamentary or inter-vivos trust, vesting or a discretionary as well as stipulations relating to what the trust may or may not do and what it may or may not distribute.

In most cases, a trust being set up will be an inter-vivos trust or in other words a living trust. It is being formed whilst the settlor is still alive.

The trust arrangement or trust deed will then also stipulates whether a beneficiary has a vesting right on trust assets or whether the trustees have full discretion as to the distribution of either trust capital or trust earning.

The settlor may go into much detail as to how he would like the trustees to manage the trust assets. However, without specifying in much detail the standard principles will apply being that the trustees will act in good faith and to the benefit of the trust as a whole.


The most common advantages of trust structures include:

    • Tax planning;
    • Avoiding probate, in other words not having assets included in your estate;
    • Wealth preservation across generations;
    • Asset protection;
    • Estate planning.


A trust is completely confidential. There is no formal register of the settlor or beneficiaries. The trustees are however required fully identify all individuals associated with a trust and to prevent money laundering.


A trust is a resident for Mauritian tax purposes and therefore subject to 15% tax rate. A trust is also subject to the possible partial exemption of 80% resulting in effective tax rate of only 3% (see section on taxes).

You are however aware that anti-avoidance legislation in various countries needs to be taken into account in ensuring that neither the settlor or any of the beneficiaries are being taxes on the income of the trust. Your discretion and dedicated awareness to this ensures that your mitigate your tax risk.


  • MUR imposes corporate taxes on its residents amounting to 15%. Subject to compliance with substance requirements your company holding a global business license may claim a 80% partial tax exemption on certain foreign sourced income. Most notably these include:
    • Foreign interest
    • Foreign dividends
    • Profits of a foreign permanent establishment and many others
  • The 80% partial exemption requires the proof of substance (ESR). The proving of substance  includes the following:
    • Certain minimum full-time employees
    • Should a GBL company be actively trading the following will also be applied:
      • 1x Employee for turnover up to USD 100m
      • 2x Employees for turnover in excess of USD 200m
      • Annual expenses amounting to USD 15 000
    • Such amount received should not have been treated as an allowable deduction in the source country.
  • Should your company or group of companies have an annual turnover in excess of Rs 500 million (+-USD = 12 500 000, ZAR = 219 000 000) will be subject to a levy on its annual gross income of 0.3% for insurance, financial institutions, service providers, property holding companies and 0.1% for all other companies. This is however not applicable to GBL license holders or companies in the tourism sector.
  • There is no taxation in Mauritius on:
    • Dividends;
    • Capital Gains
    • Withholding taxes;
    • Inheritance (estate duties);
    • Alienation of shares;
    • Donations tax; or
    • Wealth tax.


  • As is the case with your company the individual tax rate is also 15%. However, as from 2020 the Mauritian government has imposed what they refer to as a solidarity levy. This will increase your effective tax to be closer to 25% instead of the previous 15%
  • To be taxed at these rates you will have to be a Mauritian citizen or you will have to be deemed to be exclusively a resident in this country based on the applicable Double Taxation Agreement between Mauritius and your home country. You know that this will only become applicable one your residence has been confirmed or the DTA prevails.
  • To be deemed to be exclusively resident in Mauritius is fact based and your personal circumstances must be taken into account year by year. You will most probably have to be in the country for more than 6 months with a fixed place of residence.


  • VAT is levied at 15% on the supply of goods and services. The principle remains that VAT is a consumption based tax and will be levied on goods which is consumed in the country.
  • Economic Substance Regulations are also imposed in Mauritius.
  • Mauritius has specific ESR which has to be adhered to. These are required to ensure compliance with local laws as well as forming part of the Place of Effective Management requirements as discussed under the section dealing with Taxation.
  • The ESR imposed on your company is twofold requiring minimum expenditure and certain amount of staff to be appointed depending on your companies classification as well as turnover.

Overview of ESR

Category Turnover (USD) Expenditure (USD) Local Staff required
Investment holding No limit 12 000 None
Non-investment holding <100m 15 000 1
>100m 15 000 2
CIS Manager / Asset Manager <100m 30 000 1
>100m<500m 2
>500m 3
Institutions <100m 100 000 1
>100m<500m 2
>500m 3
Intermediaries NA 30 000 1
Other NA 25 000 1
  • Although ERS are imposed on companies you know that no such requirement is imposed on a trust. Your trust will therefore not be required to adhere to the ESR as its main reason for being is passive wealth preservation in accordance with the predetermined trust deed.