Understanding the Mauritian Dual Corporate Regime
The Mauritian corporate regime provides two principal legal mechanisms for foreign investors: the Authorized Company (AC) and the Global Business Company (GBC).
Selecting the right vehicle depends on whether you require tax treaty protection or pure tax-neutral offshore flexibility.
The Key Structural Differences
- Tax Residency: A GBC is considered tax-resident in Mauritius, enabling access to its 45+ Double Taxation Avoidance Agreements (DTAAs). An Authorized Company is classified as a foreign tax entity (non-resident for tax purposes) where the place of effective management is situated abroad.
- Taxation in Mauritius: An Authorized Company pays 0% tax in Mauritius on its offshore operations, while a GBC pays an effective 3% tax under the partial exemption regime.
- Substance & Cost: An Authorized Company incurs significantly lower annual maintenance and compliance costs and does not require two local resident directors, whereas a GBC requires audited accounts and local board presence.
The Decisive Rule
Opt for an Authorized Company for private passive investment holding or non-treaty consulting. Select a GBC for cross-border institutional private equity, holding operating subsidiaries in Africa, or managing regulated fund capital.
