• A GBL company

    A GBL company is deemed resident in Mauritius and benefits from the network of Mauritius tax treaties.

    A GBL company is liable to tax on its income at a flat rate of 15%.  However, a partial income exemption of 80% shall apply for specific types of income upon satisfying certain pre-defined substance requirements.

    The 80% partial exemption will be applicable to the following income streams:

    1. foreign source dividend, provided the dividend has not been allowed as a deduction in the country of source;
    2. interest;
    3. profit attributable to a foreign permanent establishment;
    4. income derived by a collective investment scheme (“CIS”), closed end fund, CIS manager, CIS administrator, investment adviser or asset manager, licensed or approved by the FSC;
    5. income from ship and aircraft leasing.
    6. interest income derived by a person from money lent through a Peer-to-Peer Lending platform operated under a licence issued by the Financial Services Commission, after the 5 year tax holiday;
    7. income derived by a company from reinsurance and reinsurance brokering activities;
    8. income derived by a company from leasing and provision of international fibre capacity;
    9. income derived by a company from the sale, financing arrangement, asset management of aircraft and its spare parts and aviation advisory services related thereto.

    A GBL company may claim actual taxes suffered at source, if higher than 15%, which can bring down the effective tax rate to 0% to the extent that it does not claim the partial exemption on that income.

    A GBL company is not permitted to have a corporate director.

    To benefit from the tax treaty network, a GBL company can apply for a Tax Residence Certificate (TRC) from the Mauritius Revenue Authority at an administrative fee.

    In demonstrating controlled and management from Mauritius, a GBL company must:

    1. have at least two resident directors in Mauritius;
    2. hold its board meetings with at least two directors from Mauritius;
    3. maintain its principal bank account in Mauritius;
    4. keep and maintain its accounting records at its registered office in Mauritius;
    5. have its statutory financial statements prepared and audited in Mauritius.


    In addition, a GBL company must, at all times, -

    1. carry out its core income generating activities in, or from, Mauritius;
    2. be managed and controlled from Mauritius; and
    3. be administered by a management company licensed by the Financial Services Commission.


    A GBL company must file its annual audited accounts with the Commission within six months of its financial year end.  A GBL company must also submit to the Mauritius Revenue Authority an annual return of income within six months of its financial year end. 

    A quarterly Advanced Payment System is applicable to companies having a gross income exceeding MUR 10 million and a chargeable income in the preceding accounting year.

    There is no capital gains tax in Mauritius.

    There is no withholding tax on dividends payments from Mauritius. There is no withholding tax on the payment of interest or royalties by Mauritius Global Business Licence (GBL) companies out of their foreign source income.

    There is no stamp duty in Mauritius and no capital duty is levied on the issue of share capital. There is no thin-capitalization rule in Mauritius.

  • An Authorised Company

    An Authorised company is not tax resident in Mauritius as such a company must have its central management and control outside of Mauritius.  Therefore, it is not be eligible for a Tax Residence Certificate (TRC) and will not benefit from the network of tax treaties.  Though, an Authorized company shall not be taxed in Mauritius on its foreign source income, it will be liable to tax in Mauritius on any local source income.

    An Authorized company must have a registered agent in Mauritius which shall be a management company, providing such services as the company may require in Mauritius, including:

    1. filing any return or document required under relevant legislation;
    2. receiving and forwarding any communication from and to the FSC, the MRA or the Registrar;
    3. undertaking measures to combat money laundering and the financing of terrorism and related offences;
    4. keeping records, including board minutes and resolutions, transaction records and such other documents as the FSC may require; and
    5. such other services as the FSC may require.

    An Authorized company must maintain financial summary to reflect its financial position and the summary of the accounts must be filed with the Commission

  • Trusts

    ChiLin Global specialises in the formation and ongoing administration of trusts and private trust companies.  Through our network, we canliaise with legal advisors in Mauritius to provide a bespoke legal drafting service for complicated trusts, if required, and further can provide all ancilliary services such as bookkeeping, preparation of accounts etc.

    Different types of trusts can be established and administered under the laws of Mauritius.

    The Trust Act 2001 makes provision for the following trusts:

    • discretionary trusts;
    • charitable trusts;
    • purpose trusts;
    • asset protection trusts; and
    • fixed trusts.

    The discretionary trust is the most commonly used offshore trust in Mauritius and is used mainly for succession planning and wealth protection.

    A trust can only be created by an instrument in writing (trust deed) and must clearly state its intention, its subject matter and the duties and powers of the trustees.

    There is no restriction on the setting up of trusts.  A trust can be established by a resident or a non-resident of Mauritius. There is no requirement for trusts to be registered in Mauritius.

    The Trust Act 2001 allows the appointment of a protector (optional) or an enforcer (for purpose and charitable trust).

    Forced heirship rule is not applicable to trusts set up under the Trusts Act 2001 of Mauritius.  Thus, a trust can be a suitable vehicle for succession planning.

    The Mauritian laws make provision for the setting up of a private trust company (a “PTC”).  This vehicle should be attractive to high net worth individuals who wish to have a structure in which they are able to exercise control over the assets in a trust through the board of directors of a PTC.  A PTC can act as trustee for a limited number of trusts.

    The potential uses of a trust include the following:

    • accumulation and preservation of wealth;
    • succession planning;
    • asset holding / asset protection;
    • estate planning;
    • employee benefits;
    • off-balance sheet transactions;
    • corporate finance / asset financing; and
    • securitization / capital market transactions.
  • Investment Funds

    ChiLin Global Limited can advise on all aspects of the establishment, structuring and regulatory issues of funds in Mauritius. We can provide a comprehensive company secretarial function as well as registered offices and can also perform all NAV calculations, accounting services, appointment of resident directors and attend to all statutory filing and reporting with the regulator.

    An investment fund can be constituted under the Companies Act 2001, the Securities Act 2005 and the Securities (Collective Investment Schemes and Closed-end Funds) Regulations 2008.

    An investment fund can be established as:

    • an expert fund;
    • a professional collective investment scheme;
    • a specialised collective investment scheme; or
    • a closed-end fund.

    An investment fund must hold a GBL licence and therefore benefits from the tax treaty network.


    Expert Fund

    An expert fund is only available to expert investors.  These are intended to be sophisticated investors who make an initial investment of at least US$100,000.  Such a fund is exempted from most of the continuing obligations generally imposed on a public collective investment scheme.  Under an expert fund, shares can be redeemed at the option of an investor.


    Professional Collective Investment Schemes

    Professional collective investment schemes offer their shares only to sophisticated investors by way of private placement.  A professional collective investment scheme is also exempted from most of the ongoing obligations and regulations generally imposed on a public collective investment scheme provided that the shares acquired by the participants are not capable of being resold to the general public.


    Specialised Collective Investment Scheme

    These are collective investment schemes that invest in real estate, derivatives, commodities or any other products authorised by the Commission.  A person wishing to establish a specialised collective investment scheme must apply to the Commission for permission to establish such a scheme.


    Closed-End Funds

    A closed-end fund is normally a fund with a limited life.  During the period of the fund, the investment is effectively “locked-in” and the investor may not redeem its shares.  This type of fund provides flexibility for an investment manager.  Once the funds have been raised, the investment manager can focus all its attention on the management of fund assets rather than having to also manage constant redemptions and new subscriptions.  The investor is intended to be a sophisticated investor who is able to bear the risk of the investment being lost and who is expected to obtain its investment return primarily through the capital appreciation of the investment.

  • Stock exchange listings

    The Stock Exchange of Mauritius (“SEM”) was established in 1989.

    The Securities (Collective Investment Schemes and Closed-end Funds) Regulations 2008 provides for the listing of funds.

    With a view to promoting the listing of funds, the SEM has recently revised Chapter 16 of the Listing Rules to make the listing process easier.

    The turnaround time for processing a listing application is two weeks and the listing fees are fairly competitive.

    A listing in Mauritius can help to enhance the substance requirements of a fund in Mauritius in order to secure treaty benefits and help in increasing the investor base of the fund.

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