Global Business Company

What is a GBL?

A company carrying out its activities principally outside of Mauritius and of which the majority of its shares, rights to vote, legal or beneficial interest are detained or controlled by a person or a group of people who are not Mauritian citizens and is managed and controlled in Mauritius, can apply for a Global Business License to operate as a Global Business Corporation (GBC).

Unlike AC, GBLs are considered tax resident in Mauritius and are subject to tax on their worldwide income. Being tax resident in Mauritius, GBL are eligible to enjoy the benefits under the various Double Taxation Avoidance Agreements (tax treaties) concluded by Mauritius.

What kind of activities can a GBL carry out?

In addition to the activities performed by an AC, a GBL can also be used to perform financial services business (subject to any additional licenses that may be required) as well as for investment holding activities.

It’s eligibility to benefits under the various Double Taxation Avoidance Agreements (tax treaties) concluded by Mauritius makes it an effective vehicle for international tax planning in cross border transactions, especially when foreign source income is in the form of dividends, interest, and capital gains.

Key characteristics of GBL

• Must perform its ‘core income-generating activities’ (CIGA) in or from Mauritius and incur a minimum level of expenditure that is proportionate to its level of activities
• Must be ‘managed and controlled’ from Mauritius and have its place of effective management in Mauritius
• Venture Corporate Services (Mauritius) Limited which is duly licensed by the FSC to act as a Management Company in Mauritius.

To determine whether a GBL is managed and controlled in and from Mauritius, the authorities shall have regard to the following matters:

• Has at least 2 directors, resident in Mauritius, of sufficient calibre to exercise independence of mind and judgement.
• Maintains, at all times its principal bank account in Mauritius.
• Keeps and maintains, at all times, its accounting records at its registered office in Mauritius;
• Prepares its statutory financial statements and causes such financial statements to be audited in Mauritius; and
• Provides for meetings of directors to include at least 2 directors from Mauritius.

Tax in Mauritius

GBLs are subject to a tax rate of 15% on their income.

However, they have the option of either claiming foreign tax suffered as a tax credit against their Mauritius tax liability or a partial exemption of 80% on certain income subject to meeting pre-defined substance requirements in Mauritius.

The criteria for meeting the substance conditions depend on the nature of the income and licensed activity. The income specified below shall be able to benefit from 80% partial exemption.

• foreign source dividends
• profits attributable to a foreign permanent establishment.
• interest and royalties; and
• income from provision of specified financial services amongst others
• Income derived by a Collective Investment Scheme (CIS), Closed-End Fund, CIS manager, CIS administrator, investment adviser or asset manager licensed as approved by the Financial Services Commission (FSC)
• Income derived by companies engaged in ship and aircraft leasing

In addition to the above, a full income tax exemption (tax holiday) for a specified period is also available if a GBL engages in certain activities such as Global Headquarters Administration, Global Treasury, or Global Legal Advisory activities.

Please contact us on office@venturecorporateltd.com for information about GBL.