Tax

Mauritius company formation in 2026: the GBC, the 3% and the two directors you must hire

Mauritius company formation: a GBC pays 15% cut to about 3% on qualifying foreign income — but needs two resident directors, a licensed manager and audit.

September 20268 min read

Mauritius is the treaty bridge into Africa and India, and it has built a serious, regulated financial centre on that position. It is not, and has not been for years, a cheap offshore filing cabinet. Anyone approaching it as one will be surprised by the bill.

Here is the short version. The main vehicle is the Global Business Company, a private company limited by shares holding a Global Business Licence from the Financial Services Commission. Formation takes about three to six weeks in practice — the FSC targets around 15 days once a complete application is filed, but management-company onboarding and KYC add time. There is no statutory minimum capital. The headline tax rate is 15%, and an 80% partial exemption on qualifying foreign-source income cuts the effective rate on that income to roughly 3%, subject to substance conditions. A GBC must have at least two Mauritius-resident directors, must be managed and controlled from Mauritius, and must at all times be administered by an FSC-licensed management company. Audit is mandatory regardless of size.

GBC or Authorised Company — decide first

This is the fork in the road and getting it wrong wastes the entire exercise.

A Global Business Company is Mauritius tax resident and taxed on worldwide income at 15%, reduced to about 3% on qualifying foreign-source income through the 80% partial exemption. Crucially, it can access the Mauritian treaty network — which is the whole point of Mauritius for most users.

An Authorised Company is non-resident, taxed only on Mauritius-source income, and cheaper to run. It cannot use the treaty network at all.

If you are structuring an investment into India or an African market to benefit from a double-tax treaty, you need a GBC and you need to pay for its substance. If treaty access is irrelevant, the Authorised Company may be sufficient — but then it is worth asking whether Mauritius is the right jurisdiction at all.

How to set up a GBC

  1. Engage an FSC-licensed management company and complete KYC and due diligence on all beneficial owners and directors. Certified, often apostilled documents are required: passport, proof of address, and bank or professional references.
  2. Reserve the name and incorporate the company limited by shares with the Registrar of Companies under the Companies Act 2001.
  3. Apply to the FSC for the Global Business Licence, appointing at least two Mauritius-resident directors and a registered office and company secretary.
  4. On licence grant, open a bank account and put substance in place — local office, board meetings held in Mauritius — along with audit and filing arrangements.

Formation is remote; no founder visit is required.

What it costs

State charges are modest. Incorporation with the CBRD is around MUR 3,000. The FSC Global Business Licence carries a USD 500 application and processing fee plus a USD 1,950 annual licence fee, and the Registrar of Companies annual fee is about USD 300.

The licensed management company is the main recurring cost, and it is not optional. Two resident directors, a registered office and a company secretary come through it. Add mandatory audit — audited financial statements to internationally accepted standards, filed with the FSC within six months of year-end, with no small-company exemption for a GBC — and the annual running cost of a Mauritian structure is comfortably into five figures in dollars.

The 3% has conditions attached

The 80% partial exemption applies to qualifying foreign-source income: foreign dividends, interest, and certain leasing and services income. It brings the effective rate on that income to roughly 3%.

It is conditional on substance. So is the tax residence certificate that unlocks treaty benefits. Management and control and substance are actively scrutinised, both by the FSC and by the treaty partners on the other side, and thin structures do lose treaty relief — Indian tax authorities in particular have a long history of testing exactly this.

A 2% Corporate Climate Responsibility levy applies to chargeable income once turnover exceeds MUR 50 million, on top of the 15% rate.

Who this is actually for

Cross-border holding and investment structures, particularly into Africa and India, where treaty access is the objective and the investor is willing to maintain and pay for genuine Mauritian substance. For a fund investing into East Africa, or a group holding Indian assets, it remains a well-designed and well-regulated answer.

It is the wrong tool for a small trading company looking for a low rate, for anyone unwilling to fund resident directors and audit, and for anyone whose plan depends on treaty benefits without substance — that plan has been failing for a decade and continues to fail. Before incorporating, confirm which vehicle you actually need, because the GBC and the Authorised Company are different products with the same postcode.

The full, dated reference for this: Company formation in Mauritius.

Frequently asked

What is the difference between a Mauritius GBC and an Authorised Company?

A Global Business Company is Mauritius tax resident, taxed on worldwide income at 15% with an 80% partial exemption cutting the effective rate on qualifying foreign-source income to about 3%, and it can access the Mauritian double-tax treaty network. It must be managed and controlled from Mauritius, have at least two resident directors and be administered by an FSC-licensed management company. An Authorised Company is non-resident, taxed only on Mauritius-source income, cheaper to run — and cannot use the treaty network at all. If treaty access is the reason you are looking at Mauritius, only the GBC delivers it.

What is the effective tax rate for a Mauritius GBC?

The headline corporate rate is 15% as of 2026. An 80% partial exemption applies to qualifying foreign-source income — foreign dividends, interest and certain leasing and services income — which reduces the effective rate on that income to roughly 3%. The exemption is conditional on meeting substance requirements, not automatic. A 2% Corporate Climate Responsibility levy applies to chargeable income where turnover exceeds MUR 50 million, on top of the 15% rate. A GBC is taxed on worldwide income, so income falling outside the partial exemption is taxed at the full 15%.

Does a Mauritius company need resident directors?

A GBC does: at least two directors resident in Mauritius, and the company must be managed and controlled from Mauritius at all times. It must also be administered continuously by an FSC-licensed management company, which typically supplies those resident directors along with the registered office and company secretary. These are not formalities — management and control are actively scrutinised, and both the partial exemption and the tax residence certificate that unlocks treaty benefits depend on the substance being real. Thin structures have repeatedly lost treaty relief.

How long does it take to set up a company in Mauritius?

About three to six weeks in practice. The Financial Services Commission targets roughly 15 days to process a complete Global Business Licence application, but that clock starts only after the licensed management company has completed onboarding and KYC on every beneficial owner and director, which requires certified and often apostilled documents including passports, proof of address and bank or professional references. Incorporation with the Registrar of Companies is quick; licensing and due diligence set the pace. Bank-account opening follows licence grant and adds further time.

How much does a Mauritius GBC cost to run?

State fees are modest: incorporation with the CBRD around MUR 3,000, an FSC application and processing fee of USD 500, an annual Global Business Licence fee of USD 1,950 and a Registrar of Companies annual fee of about USD 300. The real cost is private and recurring: the FSC-licensed management company is mandatory, and through it come two Mauritius-resident directors, a registered office and a company secretary. Add mandatory audit — audited financial statements filed with the FSC within six months of year-end, with no small-company exemption — and annual running costs reach five figures in US dollars.

Is Mauritius still useful for investing into India and Africa?

Yes, but only with genuine substance. Mauritius remains a well-regulated treaty bridge and is widely used for cross-border holding and investment structures into African markets and India. What has changed is that treaty benefits are no longer available to thin structures: a tax residence certificate, real management and control in Mauritius, and demonstrable substance are all tested, and treaty partners — Indian tax authorities notably — have a long record of challenging arrangements that lack them. Budget for two resident directors, a licensed management company, local board meetings and audit, or the treaty position will not hold.

Kate Smith
Written by
Kate Smith
Features writer · London

Follows where a family's money actually lands when it moves — and where it quietly does not.

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