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Category 1 Global Business Company (GBC1)

Governed under the Financial Services Act 2007 and Companies Act 2001 a GBC1 is a Mauritian entity which holds a valid global business licence and which carries on an approved qualified global business activity outside Mauritius as approved by the Financial Services Act 2007.

A company is normally incorporated as a branch of a foreign company, continued from a GBC2 or from another jurisdiction as a GBC1 if it is to qualify as Mauritian tax resident in order to avail of the benefits from the Mauritius double taxation treaty network.

The activities which qualify for a GBC1 licence are:
  • Asset Management
  • Consultancy Services
  • Financial Services
  • Funds Management
  • Information and Communication technology services
  • Insurance
  • Logistics and/or marketing
  • Operational Headquarters
  • Pension Funds
  • Trading
  • Any such other qualified Global Business as may be approved by the Financial Services Commission
A Category 1 Global Business Company is eligible to apply for a Tax Residence Certificate (TRC) with the Mauritius Revenue Authority (MRA). Upon satisfaction that the GBC1 meets all the conditions for being a tax resident in Mauritius, the Director of the MRA will issue a TRC to a GBC1 to prove its residency in Mauritius for tax purposes. The TRC is issued for a period of one year after which it may be renewed. The conditions to be met for obtaining a TRC are as follows:
  • The Company is centrally controlled and managed in Mauritius.
  • Two resident Directors on the Board.
  • The Company has a resident company Secretary.
  • The registered office and business address of the Company is in Mauritius.
  • The Company has a bank account in Mauritius.
  • All Meetings of the Board of directors are held at the Registered Office in Mauritius.
  • The Company records are kept at the Registered Office in Mauritius.
  • The Company’s administrator is based in Mauritius.
  • The auditors of the Company are based in Mauritius.
  • GloConsult Management Services Ltd can arrange for all these conditions to be met.
  • A GBC1 holding a TRC qualifies to take protection of the tax treaties to which Mauritius is a party.

Double Taxation Agreements

So far Mauritius has concluded 35 tax treaties and is party to a series of treaties under negotiation. The treaties currently in force are:

Barbados

Croatia

Democratic Socialist Republic of Sri Lanka

Cyprus

Germany

India

France

Italy

Kuwait

Lesotho

Luxembourg

Madagascar

Malaysia

Mozambique

Namibia

Nepal

Oman

Pakistan

People's Republic of China

Rwanda

Senegal

Seychelles

Singapore

South Africa

Swaziland

Sweden

Thailand

Uganda

United Kingdom

Zimbabwe

Belgium

Botswana

United Arab Emirates

Tunisia

State of Qatar


 

2 treaties await ratification:

Bangladesh Russia

treaties await signature with:

Egypt

Nigeria

Kenya

Vietnam

Malawi

Zambia

10 treaties are being negotiated with:

Canada

Burkina Faso

Czech Republic

Algeria

Greece

Yemen

Portugal

Ghana

Republic of Iran

Saudi Arabia

For countries with which Mauritius does not have any tax treaty, the Income Tax Act of Mauritius provides for credit for any foreign tax suffered and a deemed tax credit of 80% of the Mauritian tax payable in the absence of any proof of the foreign tax paid by the GBC1.

For Highlights of tax treaties - Click here to download

 
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