Setting Up an Offshore Company in Mauritius

An offshore company in Mauritius is a company that earns its income outside Mauritius and is used for international business, investment or holding. Mauritius is a recognised international financial centre, and its offshore vehicles give access to a wide tax treaty network. This page explains the two offshore structures, how they are taxed, the substance you must keep, and how to set one up.

If you intend to trade inside Mauritius or open a local business, see our guide to company formation in Mauritius instead.

What is an offshore company in Mauritius

Mauritius does not use the word offshore in its current law. It uses the term global business. In practice the two offshore vehicles are the Global Business Company and the Authorised Company. Both are incorporated in Mauritius but carry on their business mainly with people and companies outside Mauritius. The choice between them turns on whether you need access to tax treaties and how much presence you will keep on the island.

The two offshore structures: GBC and Authorised Company

Global Business Company (GBC)

The GBC holds a Global Business Licence from the Financial Services Commission. It is treated as tax resident in Mauritius, which gives it access to the network of more than 45 double taxation agreements. A GBC can apply the partial exemption regime, under which 80 percent of certain foreign income is exempt. That can bring the effective rate on qualifying income down to about 3 percent. In return, the GBC must meet substance rules, which are set out further down.

Authorised Company

The Authorised Company replaced the older category that used to be called the GBC 2 or GBC II, which no longer exists. An Authorised Company does not hold a Financial Services Commission licence and does not get treaty access. It is managed and controlled from outside Mauritius and is treated as non resident for tax. Its substance duties are lighter. It suits a clean holding company that does not need treaty benefits.

Comparison

Feature	Global Business Company	Authorised Company
FSC licence	Yes	No
Tax treaty access	Yes	No
Tax residence	Resident in Mauritius	Non resident
Effective tax on qualifying income	About 3 percent with partial exemption	Not applicable, no treaty benefit
Managed and controlled	From within Mauritius	From outside Mauritius
Substance requirements	Full	Light
Typical use	International trading, funds, treasury, IP	Pure holding

Tax benefits of a Mauritius offshore company

• Access to more than 45 double taxation agreements through a GBC

• Partial exemption that can reduce the effective rate on qualifying foreign income to about 3 percent

• No capital gains tax on the sale of shares and other securities

• No withholding tax on dividends paid to shareholders, wherever they live

• No exchange controls, so capital moves freely

Substance requirements you must meet

Tax benefits depend on real substance in Mauritius. A GBC that wants the partial exemption and treaty access has to show that it is genuinely run from the island. The main conditions are below.

• At least two directors who are resident in Mauritius

• The company is managed and controlled from Mauritius

• It is administered by a licensed management company

• Its main bank account is held in Mauritius

• Its accounting records are kept in Mauritius

• Financial statements are prepared and audited in Mauritius

• Core income generating activity is carried out in or from Mauritius, with adequate qualified staff and spending in line with the level of activity

An Authorised Company has lighter duties, but it still needs a registered agent in Mauritius and should not be a pure paper company, since the country where its owners live may apply its own rules to structures with no real presence.

Offshore banking in Mauritius

Every offshore structure needs a bank account, and a GBC must hold its main account in Mauritius. The banking sector is well developed and used to handling international companies. Banks run detailed checks on the owners, the directors and the source of funds, so account opening takes time and needs clean documentation. We prepare the file and introduce you to the right bank for your activity.

Who uses an offshore company in Mauritius

• Holding companies for shares in other businesses or assets

• Investment funds and private equity structures aimed at Africa and Asia

• Companies routing investment into India and sub Saharan Africa

• Intellectual property holding, licensing and royalties

• Group treasury and intra group financing

• International trading where goods do not pass through Mauritius

How to set up an offshore company in Mauritius

1. Choose between a GBC and an Authorised Company. This depends on whether you need treaty access and tax residence.

2. Appoint a licensed management company. An offshore structure has to be set up and administered through a management company licensed by the Financial Services Commission. TBI works with you on this.

3. Complete due diligence. The management company verifies the beneficial owners, directors and source of funds before any filing.

4. File for incorporation and licence. The company is incorporated and, for a GBC, the Global Business Licence application goes to the Financial Services Commission.

5. Put substance in place. Appoint resident directors, set up the registered office and arrange the local bank account so the substance rules are met from day one.

6. Open the bank account and start operating. Once the account is live the company can trade, invest or hold as planned.

Is Mauritius a reputable offshore jurisdiction

Yes. Mauritius is a member of the OECD framework and applies the Common Reporting Standard for exchange of information. It was removed from the Financial Action Task Force grey list in October 2021 and from the European Union list of high risk countries soon after. It is not on the European Union list of non cooperative tax jurisdictions. For most international users this means standard due diligence applies rather than enhanced checks. The substance rules described above are part of what keeps the jurisdiction credible.