Global Business Operations
Global business activities are carried on with non-residents and in currency other than the Mauritian rupee. Qualified global businesses are aircraft financing and leasing, asset management, consultancy services, employment services, financial services, funds management, information and communication technology services, insurance, licensing and franchising, logistics and/ or marketing, operational headquarters, pension funds, shipping and ship management, trading and such other qualified global business as may be approved by the Financial Services Commission (FSC).
Activities that may be carried on by Category 2 Global Business Licence (GBL2) holders include non-financial consultancy, IT services, logistics, marketing, shipping, ship management, trading – non financial, passive investment holding, one off transaction using a Special Purpose Vehicle (e.g.: registration of a foreign aircraft) and such other activity as may be approved by the FSC.
A company holding a Category 1 Global Business Licence (GBL1) is subject to corporate tax at a rate not exceeding 3%, after taking into consideration foreign tax credits. Companies holding a GBL2 are tax exempt but cannot avail themselves of double taxation relief under the tax treaties in force in Mauritius. They also do not fall within the purview of local taxation and are therefore not liable to Mauritius tax.
Companies holding a GBL1 are liable to tax at the rate of 15%. Dividends as well as interest paid to non-residents are tax-free. There is no other tax applicable to such companies. Companies holding a GBL1 are entitled to foreign tax credit just as other taxpayers. However where they are not able to show evidence that foreign tax has been charged on their foreign income, they will be presumed to have paid foreign tax amounting to 80% of the Mauritius tax chargeable with reference to that income.
This provision limits the tax liability of such companies to 3%.
Companies holding a GBL1 are exempt from payment of land transfer taxes, property taxes, registration duties and stamp duties. These exemptions are in respect of the qualified global business and
- in the case of a shareholder of a company holding a GBL1 or a holder of a debenture issued by that company, any security, charge, pledge or other encumbrance created over the shares or debentures issued by that company to the shareholder or debenture holder, as the case may be;
- in the case of a corporation holding a GBL1, its dealings with residents with the approval of the FSC and any authorised dealing in property situated in Mauritius.
A GBL1 holder may hold immovable property in Mauritius if appropriate approval has been obtained from the PMO.
GBL2 holders are exempt from payment of land transfer taxes, property taxes, registration duties and stamp duties. These exemptions are in respect of any transfer of property to or by the company, shares, debt obligations or other securities of the company and the assets or activities of the company. A GBL2 holder may not hold any property in Mauritius.
