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.