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Mauritius
"Mauritius structure gave us treaty access into India and East Africa that was impossible to achieve any other way. Tax efficiency and banking credibility balanced perfectly."
Company Formation & Holding Structures
- Global Business Company (GBC) (formerly Category 1 Global Business License) for international tax planning and holding structures
- 15% corporate tax rate (3% effective rate achievable on foreign-sourced income through deemed foreign tax credit for certain treaty benefits, though being phased out under OECD pressure)
- Extensive treaty network (45+ DTAs) providing reduced withholding tax rates on dividends, interest, royalties
- Popular for holding structures investing into India, China, Africa (Kenya, South Africa, Uganda, etc.)
- Participation exemption: dividends and capital gains from foreign subsidiaries largely exempt
- Substance requirements: local directors, office, employees, board meetings in Mauritius (enforced post-OECD reforms)
India & Africa Investment Gateway
- India treaty: Historically major advantage (zero capital gains tax on sale of Indian shares, reduced withholding taxes). Treaty amended 2016 to include anti-abuse provisions (Limitation of Benefits, substance requirements). Still valuable but scrutinized.
- Africa treaties: Strong treaty network across East and Southern Africa (Kenya, Uganda, Tanzania, South Africa, etc.). Mauritius serves as holding jurisdiction for private equity, venture capital, real estate funds investing in African markets.
- Treaty benefits require real substance (office, staff, management in Mauritius)
- Alternative structures emerging (Singapore, UAE also compete for India/Africa gateway role) but Mauritius remains established player
Tax & Regulatory Framework
- 15% corporate tax on net profits (no tax on capital gains, but changes being implemented)
- No withholding tax on dividends paid by GBCs to non-residents
- Treaty benefits: reduced withholding rates on income from treaty countries
- Deemed foreign tax credit mechanism being phased out (effective tax rate rising toward full 15%)
- Regulatory oversight by Financial Services Commission (FSC)
- OECD compliant: automatic exchange of information, substance requirements enforced
- Must demonstrate economic substance: local directors, employees, adequate expenditure, core income-generating activities in Mauritius
Banking & Service Providers
- Reputable banking sector (Mauritian banks, branches of international banks including Barclays, HSBC, SBM)
- Corporate banking available with proper substance and documentation
- Strong professional services sector (accountants, lawyers, corporate service providers with international expertise)
- English and French widely spoken, common law legal system
- Political stability, democratic governance (most developed African nation per HDI)
- Time zone advantage for managing African and Asian investments
- Costs moderate (higher than pure offshore, lower than Singapore/Hong Kong)
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Important Notice: Aventarys Group connects clients with licensed third-party professionals. We do not provide legal, tax, accounting, or financial advice. All services are delivered by independent licensed providers. Clients should consult their own legal and tax advisors before making any decisions.
