A GBL company can be either a private or public company limited by shares. The GBL is resident for tax purposes in Mauritius and can thus avail itself of the benefits of the double taxation treaties signed by Mauritius. The GBL may conduct business in Mauritius provided that the majority of its transactions is done outside of Mauritius and should be held or controlled by a person who is not a citizen of Mauritius.
- Its core income-generating activities must be carried out in or from Mauritius.
- Managed and controlled from Mauritius and administered by a management company.
- Should have at least two resident directors. All meetings for directors should include at least two directors from Mauritius.
- Principal bank account should be in Mauritius.
- Accounting records should at all times be kept and maintained at its registered office.
- Statutory financial statements to be prepared and audited in Mauritius.
Changes to Global Business Sector
The Mauritian Global Business Sector has undergone key transformations following the National Budget 2018-2019 and recommendations made by the OECD, in line with the OECD’s BEPS initiatives.
Subject to grand fathering/a transitional period, the ‘GBC1’ is now known as a Global Business Licence (GBL). The Category 2 Global Business License (“GBC2”) structure has phased out and there has been the introduction of the Authorised Company regime.
There are new substance requirements for the GBC, clarified in the FSC circular letter of 12 October 2018, and effective from 1 January 2019, requiring that core income-generating activities should at all times be carried out in, or from, Mauritius, by:
(a) employing, either directly or indirectly, a reasonable number of suitably qualified persons to carry out the core activities [where the employment is indirect, e.g. by a Mauritian management company (“MC”), it should be suitably qualified to conduct the core activities]; and
(b) having a minimum level of expenditure which is proportionate to its level of activities.
The Financial Services Commission (“FSC”) has illustrated circular and guidelines with respect to the new requirement of substance.
Fact Sheet – Global Business Corporation