Key Features of Category 1 Global Business Company (GBC1)

Updated time: 09 Jan, 2019, 19:35 (UTC+08:00)

A GBC 1 is licensed by the Financial Services Commission of Mauritius. It is widely used as SPV for funds or investment holding. A Mauritius Category 1 Global Business Company (GBC1) can elect to be qualified as a tax “resident” in Mauritius and thus benefit form the Double Taxation Agreement Network that Mauritius has signed with some 36 countries like India, China, UK, France, South Africa, Russia, etc..

This offers significant opportunities for international structuring and tax planning. There is no restriction on the type of business activities a GBC 1 is authorized to conduct. It can be listed on any Stock Exchange. At least one of the Directors (2 if it applies for Tax Residency Certificate) of a GBC 1 must be resident in Mauritius at all times – we do provide nominee services. All the shareholders can be non-resident.

No minimum capital requirement.
Can avail of relief under DTAs in force in Mauritius.
Allowed to employ expatriate staff.
May be private or public company.
Company may be limited by shares or unlimited or limited life company.
Shares may be subscribed by nominees but beneficial owners must be disclosed.
At least one shareholder and one resident director (can be a nominee).
Requirement for local registered office. (Read about: Virtual office Mauritius)
Shares can be issued with or without a par value.
Obligation to file annual audited accounts to the authority.
Requirements for local resident secretary.
Corporate directors are not allowed.
Only registered shared are allowed.

Fiscal Incentives

Reduced Corporate tax ( Maximum 3% after allowing for tax credits ).
Foreign tax credit available.
No withholding taxes on dividends, interests and royalties.
No capital gains tax, estate duty or inheritance tax payable.
Exemption from exchange controls.
Access to major foreign currency accounts.

Tax Residency

In order to benefit from the Double Taxation Relief, the GBC 1 is required to be tax resident in Mauritius, that is its central management and control must be exercised in Mauritius. The applicant company is required to:

Have at least two Mauritian resident board directors (can be nominees).
Appoint a resident secretary and a local auditor.
Maintain an account with the Mauritian Bank.
Maintain its registered office and all statutory records in Mauritius.
Chair all its board meetings from within Mauritius.

Once all the necessary information is available, it normally takes approximately 2 to 3 weeks to establish a GBC1. Applications are dealt with by the FSC on a first come first serve basis.

Mauritius