GLOBAL BUSINESS LICENCE COMPANY

(“GBL”) IN MAURITIUS

An Overview

Governed by the Financial Services Act 2007 (“FSA”) and the Companies Act 2001, a Global Business Licence (GBL)
Company is a Mauritian entity which is allowed to undertake lawful activity outside of Mauritius. A GBL falls under
the supervision and monitoring of the Financial Services Commission (“FSC”).

A resident corporation shall apply for a GBL where:

• the majority of its shares / voting rights / legal / beneficial interest is held or controlled, as the case may be, by
non-citizens of Mauritius; and

• such corporation proposes to conduct or conducts business principally outside Mauritius or with such category
of persons as may be specified in the FSC Rules

Main Characteristics

• The central management and control should be in Mauritius for tax residency purpose and eligibility for Tax
Residence Certificate
• Qualified to be Mauritian tax resident and can thus avail of benefits under tax treaty network
• Can benefit from the partial exemption regime on specific income
• Can be a public or private company, have a Limited Life Company status or Protected Cell Company status
among others

Requirements for a GBL

A GBL shall at all times

• Carry out its core income generating activities in, or from Mauritius, as required under the Income Tax Act;
• Be administered by a Management Company; and
• Be managed and controlled from Mauritius.

A GBL shall satisfy the following to be considered as being managed and controlled from Mauritius:

i) Has at least two resident directors in Mauritius

ii) Maintains, at all times, its principle bank accounts in Mauritius
iii) Keeps and maintains, at all times, its accounting records at its registered office in Mauritius
iv) Prepares its statutory financial statements and causes such financial statements to be audited in Mauritius; and
v) Provides for meetings of directors to include at least 2 directors from Mauritius

T: (230) 203 11 00
contact@rogerscapital.mu
www.rogerscapital.mu
 Taxation – Partial Exemption Regime

A GBL will benefit from the Partial Exemption regime, whereby 80% of the following income will be exempted from
tax:

• Income attributable to permanent establishment in a foreign country;

• Foreign dividends;
• Interests;
• Income derived by a CIS, Closed End Fund, CIS manager, CIS administrator, investment advisor or asset
manager, as licensed and approved by FSC;
• Income derived by companies engaged in ship and aircraft leasing.;
• Income derived by companies engaged in leasing and provision of international fibre capacity;
• Income derived by companies engaged in reinsurance and reinsurance brokering; and
• Income derived by companies engaged in the sale, financing arrangement and asset management of aircraft
and its spare parts, including aviation related advisory services.

A company will not be able to claim credit for foreign tax actually paid where it has claimed the partial exemption.

Claim for partial exemption can be made only if prescribed substance requirements are met.

GBL will continue to be exempted from Corporate Social Responsibility (“CSR”) obligations.

Other Features

• Incorporated within 5 - 8 working days from the time all required information is provided to the relevant
authorities
• The company must have a company secretary and a registered address in Mauritius
• Annual audited accounts need to be filed with the FSC within 6 months following the company’s financial year
end
• Registers for a private GBL filed with the ROC are not available to the public
• Annual tax return needs to be filed with the Mauritius Revenue Authority within 6 months following the
company’s financial year end
• Advance Payment System (“APS”) is applicable to all companies except where, in the preceding financial year:
(a) the company’s gross income did not exceed MUR 10 million; or
(b) it had no chargeable income
• In case the GBL is undertaking part of the activity in Mauritius, it will have to submit every year, together with
its audited financial statements:

a) a report signed by the Directors certifying that the company has complied with all the provisions of the FSA
and any regulations, FSC rules and guidelines issued under it; and
b) a certificate from its auditor confirming the percentage of the business conducted in Mauritius

T: (230) 203 11 00
contact@rogerscapital.mu
www.rogerscapital.mu