GLOBAL BUSINESS CORPORATION
The Global Business Corporation (GBC) is the successor to the Global Business Category 1 Licence (GBC 1) Governed by the Companies Act 2001 and the Financial Services Act 2007, GBCs are tax resident in Mauritius and benefit from the jurisdictions' extensive network of Double Taxation Avoidance Agreements (DTAA) pro- vided they demonstrate adequate substance in Mauritius. Tax incentives granted to GBCs include:
Flat tax rate of 15%.
80% exemption regime on
certain types of incomes
No capital gains tax,
estate duty, inheritance
or wealth tax
No withholding taxes on
dividends, interest & royalty
payments from Maurtius
No foreign
exchange controls
KEY FEATURES OF A GLOBAL BUSINESS CORPORATION
GENERAL
LOCAL
REQUIREMENTS
ANNUAL
REQUIREMENTS
- (a) Access to Double Taxation Avoidance Agreements
- (b) Confidentiality
- (c) Substance Requirements
- -Management and Control
- -Core income generating activity (CIGA)
- -Management Company
- (d) Company Secretary
- (e) Auditor
- (f) Annual meeting of shareholders
- (g) Audited Financial Statements
- (h) Tax return
- (i) FATCA / CRS filing
- (j) Corporate director
- (k) Registered Office
- (l) Tax Residence Certificate (TRC)
- (m) Tax exemption
- (a) Access Permitted
- (b) Corporate information is confidential and not available to the public
- (c) Management and control in Mauritius is demonstrated as follows:
- -Having at least two resident directors in Mauritius
- -Board Meetings to be initiated and chaired from within Mauritius.
- -Maintain the principal bank account in Mauritius
- -Maintain the registered office and all statutory (registers) and accounting records in Mauritius
- -Financial statements to be audited in Mauritius
- CIGA: The GBC shall carry out the Core income generating activity in or from Mauritius.
- The FSC will take into consideration the following factors (non-exhaustive) when assessing the enhanced substance requirements to demonstrate that the core income-generating activities of the GBL is being carried out in, or from, Mauritius.
- -Employment: either directly or indirectly (for example through a Management Company), of a reasonable number of suitably-qualified persons to carry out the core activities of the GBL
- -The minimum expenditure which should be proportionate to the level of activities of the GBL.
- -The nature and level of core income-generating activities of the GBC when assessing the above substance requirements.
- Assessment of the enhanced substance requirements will be on a case-by-case basis, taking into account the specific circumstances of each GBL.
- Management Company: A GBC must be administered by a Management Company duly licensed by the FSC
- (d) Qualified company secretary resident in Mauritius (Sphere shall act as the Company Secretary)
- (e) Appoint of an auditor in Mauritius required
- (f) Annual meeting of shareholders within 6 months of financial year end
- (g) Filing of audited financial statements with the FSC within 6 months from the Financial year end (for some special licences within 3 months from financial year end)
- (h) Filing of tax return with the MRA within 6 months from financial year end
- (i) Mauritius having signed an IGA type 1 with the IRS, FATCA / CRS filing is conducted once yearly with the MRA
- (j) Not allowed
- (k) Required (the Registered Office shall be provided by Sphere)
- (l) Application for TRC and annual renewal required if the GBC wishes to avail of DTAA benefits. TRC can be general or treaty-specific.
- (m) A Partial Exemption Regime (PER) on taxation of 80% (resulting in an effective tax rate of 3%) is available for the following income streams, provided the GBC meets its substance requirements:
- (i) Foreign dividend, subject to the amount not allowed as deduction in source country
- (ii) Foreign sourced interest income.
- (iii) Profit attributable to a permanent establishment of a resident company in a foreign country.
- (iv) Foreign source income derived by a Collective Investment Scheme, Close End Funds, CIS manager, CIS administrator, Investment Adviser or Asset Manager licenced or approved by the FSC.
- (v) Income derived by companies engaged in ship and aircraft leasing.
- The GBC is eligible to Foreign Tax Credit in accordance with the Income Tax Act (Foreign Tax Credit) Regulations. No actual foreign tax credit is allowed on foreign-source income if the GBC has claimed the 80% exemption.
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