Company Setup · Mauritius

Mauritius Global Business Company (GBC)

The Mauritius Global Business Company (GBC) is Africa's premier treaty-backed holding and investment vehicle — combining FSC regulation, a network of 46+ double tax agreements, and genuine substance at competitive cost.

GBCMauritiusFSCDTA NetworkHolding CompanyAfrica Investment
Overview

Why a Mauritius GBC?

Mauritius has established itself as Africa's leading international financial centre, with the GBC as its flagship holding vehicle. GBCs benefit from Mauritius's network of 46+ double tax agreements — including key treaties with India, South Africa, China, and France — making them the structure of choice for investments into and out of Africa and South Asia.

Marensa Advisory has hands-on GBC formation and FSC compliance experience, advising clients on GBC structure design, substance requirements, tax treaty access, and ongoing FSC regulatory obligations.

Discuss GBC Formation
What We Cover
  • GBC formation and FSC approval
  • Substance requirements: local directors, office, management in Mauritius
  • Double Tax Agreement access and treaty benefit documentation
  • AML/CFT programme and MLRO appointment
  • FATCA / CRS registration and annual reporting
  • Board of directors composition and governance
  • Bank account opening in Mauritius and internationally
  • Annual FSC filings, audit and company secretary
Key Considerations

GBC — Key Features & Requirements

Since 2019 reforms, GBCs require genuine substance. Understanding what counts as adequate substance before formation saves significant cost later.

FSC Regulation
GBCs are licensed by the Financial Services Commission (FSC) of Mauritius under the Financial Services Act 2007. The FSC issues a global business licence and supervises GBCs for ongoing compliance.
Substance Requirements
Since 2019, GBCs must have genuine substance in Mauritius — a local office, at least one locally resident director on a majority of the Board, and management and control exercised from Mauritius. The FSC actively scrutinises substance at renewal.
DTA Network
Mauritius has 46+ double tax agreements — the most extensive DTA network in Africa. Key treaties with India (exemptions for capital gains), South Africa, China, France, Luxembourg, and UAE make GBCs highly efficient for cross-border investment structures.
Qualifying Activities
A GBC must conduct qualifying business activities — holding investments, providing management services, intellectual property licensing, or similar activities. GBCs cannot trade with Mauritius-resident individuals.
Partial Exemption Regime
GBCs qualifying for the Partial Exemption Regime (PER) can exempt 80% of certain foreign-sourced income from Mauritius tax — reducing the effective tax rate significantly. PER requires meeting specific substance conditions.
FATCA / CRS
GBCs are classified as Financial Institutions under FATCA and CRS. Annual reporting to the Mauritius Revenue Authority (MRA) is mandatory for GBCs holding accounts for US persons (FATCA) or reportable persons in CRS jurisdictions.
Our Process

How We Work

01
Structure Design
We assess the investment objectives, source and destination countries, and DTA requirements to design the optimal GBC holding structure.
02
FSC Application
We prepare and submit the FSC global business licence application, including business plan, AML/CFT programme, and governance documents.
03
Substance Setup
We assist with local director engagement, registered office, management services, and all elements required to meet FSC substance requirements.
04
DTA Positioning
We document the GBC's treaty entitlement and advise on the evidence required to claim DTA benefits in each relevant jurisdiction.
05
Ongoing Compliance
We manage annual FSC filings, FATCA/CRS reporting, audit coordination, and regulatory change monitoring.
Why Marensa

Africa Investment. Mauritius Structure.

The GBC is Africa's most widely used investment holding vehicle — but post-2019 substance requirements have made formation-without-compliance a costly mistake. Substance must be genuine, not nominal.

Marensa Advisory provides end-to-end GBC advisory — from initial structure design through FSC licensing, substance setup, DTA positioning, and ongoing compliance management.

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FAQ

Common Questions

Does a GBC need a physical office in Mauritius? +

Yes. Since 2019, GBCs must have a genuine local presence — a registered office is not sufficient. A minimum local office with management infrastructure is required. The FSC scrutinises substance at licence renewal.

Can a GBC be used as a fund management vehicle? +

A GBC can hold investments, but to conduct regulated fund management activities (e.g., managing third-party client funds), an FSC financial services licence (CIS Manager, Investment Adviser) is also required.

Is a GBC the same as a previous GBC1? +

Yes. The former GBC1 (Global Business Licence 1) was rebranded as the GBC under the 2018 Financial Services (Amendment) Act. The 2019 reforms introduced stricter substance requirements and aligned GBCs with OECD BEPS standards.

How long does GBC formation take? +

GBC formation typically takes 4–8 weeks from submission of a complete application to the FSC, assuming all directors and beneficial owners pass the fit and proper assessment.

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You May Also Need

Mauritius Authorised Company
Lighter Mauritius holding vehicle without DTA treaty benefits.
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Mauritius Investment Dealer Licence
FSC licence for investment dealing activities — often held alongside a GBC.
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Mauritius FSC Advisory
Full FSC licensing and compliance advisory for Mauritius.
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