Setting Up a GBC in Mauritius: Costs, Process, Substance Requirements

A Global Business Company (GBC) is a Mauritius-incorporated company that conducts its business primarily outside the island. Holding companies, investment funds, trading companies, cross-border services businesses: if you want to be tax resident in Mauritius and access its network of 46 double taxation agreements, this is the structure.

What a GBC does

A GBC is not a shell company. Since the abolition of the old Category 1 and Category 2 licence system in 2019, every GBC must demonstrate genuine economic substance in Mauritius. The purpose is to be a real company that happens to be headquartered in Mauritius, not a brass-plate entity.

Typical uses:

• Holding structures – holding shares in operating companies in Africa, Asia, or the Middle East, taking advantage of Mauritius treaty rates on dividends, interest, and royalties
• Investment funds – Mauritius is a well-established jurisdiction for fund management, particularly for funds investing into India and Africa
• Trading companies – international trading operations that invoice and receive payment through Mauritius
• IP holding – holding intellectual property and licensing it to operating entities elsewhere
• Treasury and financing – intragroup lending and cash management

The regulatory framework is overseen by the Financial Services Commission (FSC). The key legislative reference is the Financial Services Act 2007 (as amended).

Who should consider a GBC

A GBC makes sense if:

• Your business operates across multiple countries and needs a neutral, well-regulated holding jurisdiction
• You want access to Mauritius’s network of double taxation treaties (particularly the India-Mauritius and Africa-Mauritius treaties)
• You need a structure that is OECD-compliant and meets international substance standards
• You are setting up an investment fund targeting African or Asian markets

It does not make sense for a purely domestic Mauritius business (use a standard domestic company instead) or for a solo freelancer (the Self-Employed Occupation Permit or Premium Visa are simpler routes).

The licence

A GBC requires a Global Business Licence issued by the FSC. The application is submitted through a licensed Management Company (MC), which acts as the company’s registered agent and provides the required local infrastructure. You cannot apply directly; every GBC must have a Management Company.

The FSC assesses the application based on the nature of the business, the source of funds, the beneficial owners, and the proposed substance arrangements. Processing time is typically 2-4 weeks for straightforward applications, though complex structures or unusual source-of-funds profiles can take longer.

Costs

Setup costs (one-off):

• FSC application fee: $500
• Company incorporation (Registrar of Companies): Rs 5,000 ($108)
• Management Company setup fee: $2,000-$5,000 (varies by MC and complexity)
• Legal opinion (if required): $1,000-$3,000
• Total setup: $3,500-$8,500

Annual recurring costs:

• FSC annual licence fee: $1,750
• Management Company annual fee: $5,000-$15,000 (covers registered office, company secretary, compliance, filing)
• Audit fees: $3,000-$10,000 (GBCs must be audited annually)
• Tax return preparation: $1,500-$3,000
• Local directors (if using MC-nominated directors): $2,000-$5,000 per director per year
• Total annual: $13,000-$35,000

These are indicative ranges. A simple holding company at the lower end; a multi-entity fund structure at the higher end. The Management Company fee is the largest variable: shop around, as pricing differs significantly between the 160+ licensed MCs in Mauritius.

Substance requirements

This is the area that has changed most since 2019 and is the reason many older GBC structures have been restructured or closed. Mauritius now enforces substance requirements aligned with the OECD Forum on Harmful Tax Practices and the EU Code of Conduct.

A GBC must demonstrate:

1. Core income-generating activities in Mauritius

The company’s core revenue-generating activities must be conducted in or from Mauritius. For a holding company, this means investment decisions are made in Mauritius. For a trading company, it means contracts are negotiated and signed here. For a fund, it means portfolio management is directed from Mauritius.

2. Local management and control

The company must be managed and controlled from Mauritius. In practice:

• At least two directors must be resident in Mauritius (they can be MC-nominated directors, but increasingly the FSC expects at least one independent director with genuine decision-making authority)
• Board meetings must take place in Mauritius (physical presence or a Mauritius-based quorum for virtual meetings)
• Minutes must reflect genuine deliberation, not rubber-stamping

3. Adequate expenditure in Mauritius

The company must incur expenditure proportionate to its activities. There is no fixed minimum, but the FSC will question a company that claims to conduct business from Mauritius while spending nothing here. Management Company fees, director fees, office costs, and employee costs all count.

4. Qualified employees

The company should employ or have access to suitably qualified persons to conduct its activities. For many GBCs, the MC provides these personnel. Larger operations may need their own staff.

5. Physical presence

A registered office address is mandatory and provided by the MC. For more complex operations, dedicated office space with staff is expected.

The FSC conducts periodic substance reviews and can revoke a licence if substance is not maintained. Since 2020, enforcement has been meaningful: several GBCs have had licences revoked or been required to restructure.

Tax treatment

GBCs are tax resident in Mauritius and subject to the standard 15% corporate tax rate. However, a GBC can claim a credit for foreign tax paid on income sourced outside Mauritius, which is deemed to be the higher of the actual foreign tax paid or 80% of the Mauritius tax. In practice, this mechanism results in an effective tax rate of around 3% on foreign-source income.

Use the Mauritius tax calculator to estimate your own tax liability.

Since January 2025, the Qualified Domestic Minimum Top-Up Tax (QDMTT) applies to GBCs that are part of multinational groups with consolidated revenue above EUR 750 million. This ensures an effective minimum tax rate of 15% for large groups, neutralising the benefit of the deemed foreign tax credit for those entities.

For GBCs outside the Pillar Two scope (the vast majority), the effective rate of approximately 3% on foreign-source income remains available. For a broader view of the corporate tax framework, see the tax guide.

Treaty access

Mauritius has 46 double taxation agreements in force, with strong coverage across Africa (South Africa, Kenya, Uganda, Mozambique, Senegal, Rwanda, and others) and Asia (India, China, Malaysia, Singapore, Thailand). The Mauritius double tax treaty table lists the current withholding rates country by country. The India-Mauritius treaty, amended in 2016, now imposes source-country capital gains tax on share disposals, but remains beneficial for dividend flows (5% treaty rate vs 20% domestic rate).

Treaty access is conditional on passing the Limitation on Benefits (LOB) test and the Principal Purpose Test (PPT) under BEPS Action 6. The FSC issues Tax Residence Certificates (TRCs) to GBCs that meet the substance requirements, which is the document your counterparty’s tax authority will require to apply treaty rates.

Setup process: step by step

1. Choose a Management Company – compare fees, responsiveness, and sector expertise. Ask for references.
2. Prepare documentation – business plan, source of funds evidence, beneficial ownership details, passport and address proof for all directors and shareholders, and bank reference letters.
3. MC files the application – the MC submits to the FSC and the Registrar of Companies simultaneously.
4. FSC due diligence – the FSC reviews the application and may request additional information. Timeline: 2-4 weeks for straightforward applications.
5. Licence issued – the GBC is now operational. The MC opens a local bank account (this can take an additional 2-6 weeks depending on the bank’s own compliance process).
6. Apply for TRC – the MC applies for a Tax Residence Certificate from the Mauritius Revenue Authority. This is essential for accessing treaty benefits.

Total timeline from engagement to operational GBC with a bank account: typically 6-12 weeks.

Ongoing compliance

• Annual audited financial statements (filed with the FSC and Registrar)
• Annual tax return (filed with the Mauritius Revenue Authority)
• Annual licence fee to the FSC
• Beneficial ownership register maintained and updated with the FSC
• Substance documentation maintained and available for review
• Beneficial ownership rules tightened under Finance Act 2025, with earlier compliance deadlines

Common mistakes

• Choosing the cheapest MC – the fee difference between a good MC and a bad one is $5,000-$10,000 per year. The cost of a compliance failure, revoked licence, or failed audit is far higher.
• Rubber-stamp boards – the FSC and treaty partners can look through nominee directors who do not exercise real authority. Invest in directors who understand the business.
• Ignoring Pillar Two – if your group is anywhere near the EUR 750 million revenue threshold, get specialist advice before structuring through Mauritius.
• Treating the TRC as automatic – it is not. The MRA can refuse a TRC if substance is not demonstrated. Do not assume treaty access until you have the certificate.

For the broader business environment, see the business and investment guide. For questions about structuring, get in touch or subscribe to the newsletter for updates on regulatory changes.