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