Global Business Licence (GBL)
Mauritius International Company Structure
Mauritius Global Business Licence: International Company Structure with Tax Treaty Access
The Global Business Licence (GBL) is the cornerstone of the Mauritius international financial centre. Issued by the Financial Services Commission (FSC) under Section 71(1) of the Financial Services Act 2007, the GBL is designed for foreign-controlled companies that conduct business principally outside Mauritius. A company holding a GBL is commonly referred to as a Global Business Company (GBC).
The GBL replaced the former Category 1 Global Business Licence (GBC1) in January 2019, as part of Mauritius’s alignment with OECD Base Erosion and Profit Shifting (BEPS) standards. At the same time, the former GBC2 category was abolished and replaced by the Authorised Company structure.
A GBL company provides access to the Mauritius network of 46 Double Taxation Avoidance Agreements (DTAs), enabling significant tax efficiency on cross-border transactions involving dividends, royalties, interest, and capital gains. This treaty network, combined with a robust regulatory framework and a well-established pool of professional service providers, makes Mauritius one of the most widely used international financial centres for investment into Africa and Asia.
Who Should Use a Mauritius GBL?
The GBL is widely used for a range of international business activities. Common uses include:
Investment holding:
Holding shares in subsidiaries or associated companies in Africa, India, and other treaty partner jurisdictions, benefiting from reduced withholding taxes on dividends and interest.
International trading:
Companies that buy and sell goods or services across borders, using Mauritius as the contractual and operational hub.
Fund structures:
Collective investment schemes, closed-end funds, and fund management entities licensed by the FSC.
Treasury and finance:
Intra-group lending, cash pooling, and treasury management for multinational groups.
Intellectual property holding:
Licensing of IP rights through a Mauritius entity to benefit from treaty-reduced royalty withholding rates.
Fintech and technology:
Technology companies providing services to international clients from a Mauritius base.
Aircraft and ship leasing:
Leasing structures that benefit from the partial exemption regime on leasing income.
The GBL is not intended for businesses that trade primarily with Mauritius residents. If your business will operate locally, a Mauritius domestic company is the appropriate structure.
GBL Requirements & Eligibility
To qualify for a Global Business Licence, the applicant company must satisfy the following conditions:
Foreign Controlled
The majority of shares, voting rights, or beneficial interests in the company must be held or controlled by a person who is not a citizen of Mauritius. This is a fundamental eligibility criterion — the GBL is designed for international businesses, not locally owned companies.
Business Conducted Principally Outside Mauritius
The company must propose to conduct its business principally outside Mauritius, or with such category of persons as may be specified by FSC rules. The FSC assesses each application to determine whether the ultimate purpose of the business is an investment or service made or provided outside Mauritius.
Managed and Controlled from Mauritius
The GBL must be managed and controlled from Mauritius. This means the company must have at least two directors who are resident in Mauritius and of sufficient calibre to exercise independence of mind and judgment. Board meetings must be held in Mauritius, the principal bank account must be maintained in Mauritius, and accounting records must be kept at the company’s registered office in Mauritius. Statutory financial statements must be prepared and audited in Mauritius.
Administered by a Licensed Management Company
Every GBL must be administered by a Management Company licensed by the FSC. The Management Company acts as the intermediary between the GBL and the FSC, and is responsible for ensuring the company meets its ongoing regulatory, compliance, and substance obligations. Intrasia Management (Mauritius) Limited, our sister company within the Intrasia Group, holds a Management Company licence from the FSC and provides this service.
Substance Requirements for a Mauritius GBL
Substance is the single most important concept for any GBL. The FSC and the Mauritius Revenue Authority (MRA) both require a GBL to demonstrate genuine economic presence in Mauritius. This is not optional. It is a condition of maintaining the licence and accessing the partial exemption regime.
The substance requirements are:
Core Income-Generating Activities (CIGA):
The company must carry out its core income-generating activities in or from Mauritius. What constitutes CIGA depends on the nature of the business. For a holding company, this means making strategic decisions about investments; for a trading company, this means negotiating and concluding contracts.
Qualified Staff:
The company must employ, directly or indirectly, an adequate number of suitably qualified persons to conduct its CIGA in Mauritius.
Minimum expenditure:
The company must incur a minimum level of expenditure proportionate to its level of activities.
Physical office:
The company must maintain office premises in Mauritius.
Principal bank account:
The company’s principal bank account must be in Mauritius, with signatory rights held by the resident directors and/or Management Company, not solely by the overseas beneficial owners.
Board meetings:
Board meetings must be held in Mauritius, chaired by resident directors.
Accounting records:
Records must be maintained at the registered office in Mauritius, with financial statements prepared and audited locally.
Companies that fail to meet substance requirements risk losing access to the partial exemption regime, being denied a Tax Residence Certificate by the MRA, or having their GBL revoked by the FSC.
GBL Tax Regime:
Partial Exemption and
Effective Tax Rate
The standard corporate tax rate in Mauritius is 15%. However, GBL companies that meet the substance requirements can claim an 80% partial exemption on qualifying foreign-source income, resulting in an effective tax rate of 3%.
The partial exemption applies to the following categories of income:
Foreign-source dividends (provided the dividend is not allowed as a deduction in the source country).
Interest income (excluding banks, non-bank deposit-taking institutions, insurance companies, leasing companies, and companies providing factoring, hire purchase, or credit sale facilities).
Profit attributable to a foreign permanent establishment of a Mauritius-resident company.
Income derived by collective investment schemes, closed-end funds, CIS managers, CIS administrators, investment advisers, and asset managers licensed by the FSC.
Income from aircraft and ship leasing derived by companies engaged in these activities overseas.
Where the partial exemption is claimed, no credit for foreign taxes (actual tax credit, underlying tax credit, or tax sparing credit) is available. Companies must choose between the partial exemption and the foreign tax credit. They cannot use both.
There is no withholding tax on dividends, interest, or royalties paid by a GBL to non-residents.
Finance Act 2025: Changes Affecting GBL Companies
The Finance Act 2025, enacted in August 2025, introduced several changes that affect GBL companies:
Qualified Domestic Minimum Top-up Tax (QDMTT)
A Qualified Domestic Minimum Top-up Tax of 15% now applies to subsidiaries and holding companies of multinational enterprise groups with consolidated annual revenue of EUR 750 million or more. This aligns Mauritius with the OECD Pillar Two Global Minimum Tax framework. The QDMTT ensures that even where the partial exemption would otherwise reduce the effective rate below 15%, the top-up tax brings it to the global minimum. This primarily affects large multinational group structures rather than mid-sized GBL operations.
Tightened Partial Exemption Eligibility
The eligibility criteria for the Partial Exemption Regime have been tightened. The 80% exemption now applies only if the income is derived from activities covered under the company’s GBL licence and the company satisfies the prescribed substance conditions. This reinforces the importance of ensuring your GBL’s actual activities match its licensed scope.
Fair Share Contribution
GBL-licensed companies are excluded from the separate Fair Share Contribution that applies to domestic companies with chargeable income above MUR 24 million. This avoids a double layer of additional taxation for GBL companies already subject to the QDMTT.