The Investment Brief
A consortium of Middle Eastern and European institutional family offices established a $60 million specialized infrastructure fund targeting renewable solar and logistics assets in Kenya, Ghana, and Nigeria.
Key requirements included political risk mitigation, expropriation protection, stable multi-currency repatriation, and predictable dividend withholding tax efficiency.
The Mauritius Structuring Framework
Connection Middle East and our Mauritian associates orchestrated the cross-border investment model:
- Established a Mauritius Global Business Company (GBC) holding vehicle licensed by the Financial Services Commission.
- Utilized Mauritius's extensive network of Bilateral Investment Treaties (BITs) and Double Tax Avoidance Agreements (DTAAs) across the target African states.
- Mitigated dividend withholding taxes from 15%–20% down to 5%–10% under treaty covenants.
- Implemented English Common law dispute escalation clauses routed to the Mauritius International Arbitration Centre (MIAC).
Measured Results
The fund deployed capital safely, protected assets against unilateral regulatory shifts via investment treaty rights, and secured an average 8.4% tax-efficient dividend distribution yield.
