Mauritius — Global Business Company (GBC) 2026

The Global Business Company (GBC) is Mauritius's primary tax-resident corporate vehicle for international operations. It is regulated by the Financial Services Commission (FSC) under the Financial Services Act 2007 and administered exclusively through FSC-licensed management companies. Unlike offshore structures that offer zero regulation and zero tax, the GBC is a substantive, treaty-accessible, FSC-supervised entity — which is precisely why it works commercially where purely offshore structures fail.

Three things distinguish the GBC from every comparable offshore alternative. First, the ~3% effective tax rate is achieved through a 15% statutory rate with an 80% partial exemption on qualifying income categories — not through a special low-tax regime that OECD bodies scrutinize, but through a mainstream exemption framework that survives treaty abuse challenges. Second, the 46+ double taxation agreements — particularly with India, China, South Africa, the UAE, and most of Africa — provide withholding tax relief that offshore structures simply cannot access. Third, the FSC's Tax Residence Certificate (TRC) is the instrument that unlocks these treaty benefits, and the MRA only issues TRCs to companies that genuinely satisfy Mauritius's substance requirements.

Getting all three of these right simultaneously is where GBC structuring becomes genuinely complex — and where most errors occur.

The GBC is subject to Mauritius corporate income tax at 15% on its net taxable income — the same statutory rate as any other Mauritius-resident company. The ~3% effective rate is not a special offshore rate; it comes from the Partial Exemption Regime (PER) under the Income Tax Act, which grants an 80% exemption on specific categories of income for GBCs that meet the substance requirements.

The income categories eligible for the 80% exemption include: foreign-source dividends, interest income, royalties from intellectual property, income from securities transactions, income from collective investment scheme management, and gains from the disposal of shares. Not all income a GBC earns automatically qualifies — the exemption applies to specific categories, and the MRA's assessment of whether a company genuinely earns its income in Mauritius is a real gate, not a formality.

Additionally, the PER can in some cases provide exemptions ranging from 80% to 95% depending on the specific category and activity. GBCs that hold special licences (such as fund management, investment advisor, or insurance) can access 95% exemptions on qualifying income from those licensed activities.

The alternative to the PER is the foreign tax credit method — where a GBC claims a credit for taxes paid in the source country against its Mauritius liability. This was the original mechanism before the PER was introduced, and some structures still use it where the foreign tax suffered exceeds what the PER would produce. Zitadelle AG advises on which method is more efficient for specific income structures.

The CIGA (Core Income Generating Activities) requirement is the mechanism that determines whether a GBC qualifies for the PER. The FSC made this explicit from 1 January 2022: CIGA compliance is only required for GBCs that claim the partial exemption. A GBC that does not claim the PER — and pays the full 15% — is not required to demonstrate CIGA. In practice, almost every GBC formed for international tax efficiency purposes claims the PER, which means CIGA compliance is effectively universal.

What does CIGA actually mean? The FSC's guidance is deliberately flexible because it has to accommodate the enormous variety of activities that GBCs conduct — holding companies, fund managers, investment advisors, commodity traders, treasury companies, and more all have different CIGA profiles. The three conditions that must all be satisfied are:

Separate from CIGA, a GBC must demonstrate that it is managed and controlled from Mauritius for both FSC regulatory purposes and to obtain and maintain the MRA Tax Residence Certificate. This is the concept that determines where the company is actually run from — as distinct from where it is incorporated.

The FSC assesses management and control against the following indicators — a GBC should satisfy all of them, not just some:

The Tax Residence Certificate (TRC) is issued by the Mauritius Revenue Authority (MRA) and is the document that enables a GBC to claim benefits under Mauritius's double taxation agreements. Without a valid TRC, a GBC cannot substantively rely on any of the 46+ DTAs — treaty partners' withholding agents will not reduce their withholding rates without it.

The MRA only issues TRCs after its own independent assessment of the GBC's substance — it does not simply rubber-stamp FSC approvals. The MRA will assess the company's CIGA activities, management and control indicators, and genuine economic presence in Mauritius before issuing or renewing the TRC. This dual-gate structure (FSC licensing + MRA TRC) is what gives Mauritius its credibility with treaty partners — the assessment is genuine, not administrative.

This dual assessment process is also why GBCs formed purely to extract treaty benefits without genuine substance consistently fail. Mauritius's reputation — and its retention on treaty partner whitelists — depends on the MRA and FSC running real assessments.

The GBC and the Authorised Company (AC) are the two FSC-licensed corporate vehicles in Mauritius for international business. They serve fundamentally different purposes, and choosing the wrong one is a common mistake.