Mauritius significantly changes its corporate substance requirements

African Tax Newsalert

Effective January 1, 2015, Category 1 Global Business Companies (GBC 1s) must have a local presence that could be reasonably expected from a corporation ‘managed and controlled’ in Mauritius. A GBC 1 is a resident company for taxation purposes and generally benefits from Mauritius’ extensive double tax treaty network as well as its lower domestic corporate and withholding tax rates.

Under current law, Mauritius recognizes a GBC 1 entity if it satisfies limited substance requirements, but under the new rules, corporations will have to meet at least one additional requirement. Therefore, multinationals should review their Mauritian structures to ensure compliance with the new substance requirements before they take effect.



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