A resident corporation having its principle place of effective management in Mauritius and meeting the following criteria shall mandatorily be required to apply for a Global Business Licence.

1. Citizenship Test
The majority of shares or voting rights or legal or beneficial interest in a resident corporation (other than a bank licensed by the Bank of Mauritius and such other corporation as may be specified in FSC rules) are held or controlled by a person who is not a citizen of Mauritius.

2. Conduct of Business Test
The corporation proposes to conduct business principally outside Mauritius or with such category of persons as may be specified in FSC Rules.

A corporation holding a Global Business Licence (GBC) may be used for structuring investments, holding intellectual property and providing financial services, or provide such other activities requiring other special licenses, amongst others.

A GBC must at all times:

• Carry out its core income generating activities in or from Mauritius by
  • employing either directly or indirectly a reasonable number of qualified persons to carry out the core activities, and
  • having a minimum level of expenditure, which is proportionate to its level of activities
• Be managed and controlled from Mauritius; and
• Be administered by a management company.

Tax Features

GBCs are tax resident in Mauritius. Subject to meeting relevant conditions where applicable, the main tax features are as follows:

• Access to the extensive network of Double Taxation Avoidance Agreements (DTAAs) which Mauritius has with other countries;
• Eligible to the partial exemption regime under which 80% of certain income are exempted from income tax;
• Eligible to underlying tax credit on dividends if shareholding in the company paying the dividend is directly or indirectly greater than 5%;
• Eligible for tax sparing benefits;
• No thin capitalization rules, earning stripping and controlled foreign company regulations;
• Exempted from capital gains tax in Mauritius.