Description
Mauritius is situated in the south-west of the Indian Ocean, 2 000 km from the east coast of Africa. The island lies just within the Tropic of Capricorn 20° south of the Equator and 57° east of Greenwich.
It is of volcanic origin and forms part of the group of islands commonly known as the Mascarenes, which comprise also the Reunion Island and Rodrigues Island.
The island of Mauritius which has an area of 1 864 sq. km is almost entirely surrounded by coral reefs. Within those reefs are peaceful lagoons, ringed by smooth beaches of white coral sand. There is a break in the coral reef only in the south where part of the coast is steep and rocky.
Mauritius has a maritime climate, tropical during summer and sub-tropical during winter. The summer months extend from October to March and winter from June to September.
During the greater part of the year, trade winds blow from the south-east; they are steadier from May to October. In summer, the winds are lighter, periodically interrupted by cyclonic disturbances. The rainfall varies according to the height above the sea level, and ranges from 15mm in October to 187mm in February. The heavy rains occur mainly between January and May, although there are no well-defined rainy and dry seasons. The vegetation remains green throughout the year. In the centre of the island, the average mid-day temperature in July-August is 19°C and dawn temperature 13°C, increasing to 25°C and 19°C respectively by February. Near sea-level all temperatures are about 5°C higher, reaching an average of 30°C at mid-day in February.
The World Bank’s Ease of Doing Business Report 2020 ranks Mauritius at the 13th position out of 190 economies. The reforms implemented by Government to facilitate business over the last years have helped the country position itself amongst the top-ranking economies in the world for ease of doing business. In the wake of daunting challenges, the sector endeavours to gear up for greater competition and higher productivity level by improving export preparedness as well as facilitating access to emerging markets both locally and globally while ensuring effective protection of consumers.
Authorised Company (AC)
An Authorised Company (AC) is an extremely versatile corporate entity for the purpose of e.g. a private portfolio holding company, trading company, aircraft and ship registration and property holding companies. An AC may be locally incorporated in Mauritius or registered as a branch of a foreign company. It is licensed and regulated by the Financial Services Commission of Mauritius.
Features
- does not need to submit audited accounts but a financial summary needs to be filed with the Financial Services Commission in Mauritius (FSC) within 6 months of the year end;
- high degree of confidentiality;
- may not engage in reserved activities such as financial services, banking and insurance;
- may not hold any account in a bank in Mauritian currency (MUR);
- requires a management company such as Lemuel Corporate & Trust Management Ltd as a registered agent at all times;
- all meetings can be carried out where the directors or shareholders deem fit; and
- may hold shares in a Global Business Corporation (GBC).
Regulatory Requirements
- the majority of shares or voting rights or the legal or beneficial interest in the company, are held or controlled, as the case may be, by (a) person(s) who is/are not a citizen(s) of Mauritius;
- the activity(ies) of the Company is/are being conducted principally outside Mauritius or with such category of persons as may be specified in FSC Rules; and the company has its place of effective management outside Mauritius.
Taxation
- treated as non-resident for tax purposes in Mauritius;
- required to file an annual tax return within the Mauritius Revenue Authority (“MRA”).
Purposes
- once-off transaction using a Special Purpose Vehicle (SPV);
- any other activity as may be approved by the FSC in Mauritius;
- activities where double taxation treaty considerations do not apply;
- activities where a physical presence in Mauritius is not required;
- non-financial consultancy;
- passive investment holding;
- shipping and ship management;
- non-financial trading;
- marketing services;
- logistics services; and
- IT services.
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Global Business Corporations (GBC)
A Global Business Corporation (GBC) can carry out any financial or non-financial business activity, e.g. investment holding, asset management, credit finance, custodian services (non-CIS), distribution of financial products, factoring, leasing, occupational pension schemes, pension fund administration, pension scheme management, retirement benefits schemes, superannuation funds, registrar and transfer agencies, treasury management and such other financial business activities as may be specified by the Financial Services Commission (FSC), the non-banking financial activities regulator.
Features
Can either be a private company, a public company or a foreign company registered under the companies’ Act of 2001
- Company may be limited by share or guarantee, or by both.
- Open bank accounts in local and foreign currencies.
- Claim double taxation relief under the various treaties signed by Mauritius.
- Can conduct business in Mauritius, deal with a person resident in Mauritius and can hold shares or other interests in a corporation resident in Mauritius.
- Audited accounts filed within 3-6 months after year end.
Tax Advantages
- Exempted capital gains tax in Mauritius;
- Eligible for tax sparing benefits;
- If shareholding paying dividend in the GBC is directly/indirectly >5%, eligible to underlying tax credit on dividend;
- A GBC is considered to be tax resident in Mauritius and is subject to corporate tax at 15%. However, a partial tax exemption of 80% will apply on specific types of income including:
– Foreign-source dividends derived by a company;
– Interest derived from overseas by a company other than a bank;
– Profit attributable to a permanent establishment of a resident company in a foreign country;
– Foreign-source income derived by a collective investment scheme (CIS), closed-end fund, CIS manager, CIS administrator, investment adviser or asset manager, licensed or approved by the Financial Services Commission; and
– Income derived from overseas by companies engaged in ship and aircraft leasing.
Where a company has claimed the partial exemption, no credit for foreign taxes in the form of actual tax credit, underlying tax credit and tax sparing credit will be available. The definition of foreign-source income has been changed to “income which is not derived from Mauritius”.
- The expanding network of DTAs has further reinforced Mauritius as a tax efficient jurisdiction and is also one of the prime reasons explaining the growing investment in GBCs.
- A GBC wishing to benefit from the tax relief under the Double Taxation Agreements requires a Tax Residence Certificate (TRC).
Regulatory Requirements
- the majority of shares / voting rights / the legal / beneficial interest are held or controlled, as the case may be, by a non-citizen of Mauritius;
- conducts business principally outside Mauritius; and.
- Management Company as Secretary.
- Carry out its core income generating activities in, or from, Mauritius by:
– Employing, either directly or indirectly, a reasonable number of suitably qualified persons to carry out the core activities;
– Having a minimum level of expenditure which is proportionate to its level of activities;
- Be managed and controlled from Mauritius; and
- Be administered by a Management Company.
In order to obtain a tax residence certificate, a company must demonstrate that the business is being controlled and managed from Mauritius. This is known as the Control and Management Test.
The five criteria to pass the control and management test are that the GBC:
- have at least 2 directors, resident in Mauritius, of sufficient caliber to exercise independence of mind and judgement;
- maintain, at all times, its principal bank account in Mauritius;
- keep and maintain, at all times, its accounting records at its registered office in Mauritius;
- prepare its statutory financial statements and causes such financial statements to be audited in Mauritius; and
- provide for meetings of directors to include at least 2 directors from Mauritius.
Required documents for the company formation:
- Copy of Notarized Passport;
- Scan of Notarized Address Proof – It can be utility bill (Gas, Water, Electricity,…) which is not issued later than 3 months and the content must be in English. If it’s not, an English translation is required;
- Bank reference (with sign printed or Certify true copy)
- Signed CV/ Resume
Mauritius Offshore Banking
- AfrAsia Bank Limited
- Bank of Baroda
- Bank One Limited
- Banque des Mascareignes Ltée
- Barclays Bank PLC
- Bramer Banking Corporation Ltd
- Deutsche Bank (Mauritius) Limited
- Habib Bank Limited
- HSBC Bank (Mauritius) Limited
- Investec Bank (Mauritius) Limited
- Mauritius Post and Cooperative Bank Ltd
- P.T Bank Internasional Indonesia
- SBI (Mauritius) Ltd
- Standard Bank (Mauritius) Limited
- Standard Chartered Bank (Mauritius) Limited
- State Bank of Mauritius (SBM) Ltd
- The Hongkong and Shanghai Banking Corporation Limited (Mauritius Branch)
- The Mauritius Commercial Bank (MCB) Ltd
GIA can help you to open your Corporate Bank Account for your Mauritius or Offshore Company including cheque books, debit/credit cards and Internet Banking facilities. The requirements for bank account opening depend on where you want the account to be opened. These banks do not normally require personal presence of the authorized signatories as such.
Minimum balance requirements and bank charges
The minimum balance requirements and bank charged for a company bank account in Mauritius. The approval for offshore accounts is done on a case-by-case basis. Due to our excellent banking relationships with the banks, GIA can assist you in setting up a corporate bank account quickly and easily.
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