February 2020
Company and Trust registration in Mauritius:
Different Business entities in Mauritius:
The Mauritius Global Business Company (GBC):
GBC can be setup with:
- A minimum capital of $1
- One shareholder
- Two directors, who both must be ordinarily residing in Mauritius
The Financial Services Commission also frequently request additional evidence that the company is managed from Mauritius, including a local corporate bank account.
The Mauritius GBC is considered as a resident entity and will hence have to pay tax in Mauritius over its global earnings, but at an attractive rate of 3% compared to 15% for other resident companies.
Such scheme can allow the company:
- Not to pay corporate tax in other countries
- To benefit from withholding tax exemption on dividends and interest remitted from one of the 44 countries which have signed a double tax avoidance agreement with Mauritius.
To benefit from reduced Mauritius corporate income tax, GBC companies must meet the following requirements:
- Investment Holding companies (excluding IP): minimum local expenses of $12,000.
- Non-investment Holding companies: minimum local expenses of $15,000 and at least 1 staff member in Mauritius (2 for entities with turnover above $100,000,000 annually)
- Asset Management companies’ minimum local expenses of $30,000 and at least 1 staff member in Mauritius (2 for entities with turnover between $100,000,000 and $500,000,000 annually)
A GBC is the right type of business entity for holding activities, as well as regulated services requiring a license, for instance financial services or insurance.
The Mauritius Limited Liability Partnership (LLP):
Foreigners can register limited liability partnerships in Mauritius with:
- Only two partners, who both can be non-residents and limited partners
- A minimum capital of $1 per partner
- A manager, who needs to be a resident in Mauritius.
After registration of the partnership, it is necessary to obtain a GB license, or the partners will be subject to Mauritius personal income tax on the income channelled through the entity.
The Mauritius LLP is a good vehicle for the provision of legal and consulting services by overseas partners who are residing in multiple countries.
The Mauritius Authorized Company:
The Mauritius authorised company can be setup with:
- A minimum capital of $1
- One shareholder
- One director, who do not need to be resident in Mauritius.
Setting up a Mauritius authorised company requires a resident registered agent, in charge of maintaining company records.
It is mandatory for an authorised company to file a return of its income with the Mauritius Revenue Authority.
Authorised companies must conduct business and have their place of effective management outside of Mauritius.
Authorized companies can be used to conduct international trade or as Holding vehicle.
The Mauritius Limited Liability Company (Proprietary company):
The LLC requires:
- At least 1 shareholder at incorporation, who can be of any nationality and country of residence
- Only $1 of share capital
- One director, who must be resident in the country.
- LLC is subject to Mauritius corporate tax at a rate of 15% and annual financial statements filing requirements.
LLC should only be used to setup a local business in Mauritius.
Holding assets with a Mauritius entity:
Mauritius offshore trust:
Foreigners can register offshore trusts in Mauritius free of local taxation, provided all assets, settlors and beneficiaries are non-residents.
There is no need to register the Trust in Mauritius or appoint a local licensed trustee, although this is recommended for additional asset protection.
Mauritius offshore trusts are attractive for family wealth management and asset protection. They are also commonly used as special purpose vehicles for investment activities in Africa.
