Global Business Licenses
A GBC1 is considered a tax resident in Mauritius and can benefit from the country’s double taxation treaties. Up to 31 December 2018, a GBC1 may claim a foreign tax credit in respect of the actual foreign tax suffered or 80% presumed foreign tax credit, whichever is higher. As such, a GBC1 has a maximum effective corporate tax rate of 3%.
As from 01 January 2019, GBC1 will be known as Global Business License and a partial exemption regime will be introduced whereby 80% of specified income will be exempted from income tax. The exemption will be granted to all companies in Mauritius, except banks, and shall apply to the following income – (i) foreign source dividends and profits attributable to a foreign permanent establishment; (ii) interest and royalties; and (iii) income from provision of specified financial services. Companies licensed by the Financial Services Commission, claiming the partial exemption, will have to satisfy pre-defined substantial activities requirement of the Commission.
Operational aspect of a GBL
The GBL is generally used for:
•Investment in listed securities
To qualify as tax resident in Mauritius, the GBL company must meet a number of criteria to show substance, including:
• It must be centrally managed and controlled from Mauritius;
• The core income generating activities of the GBL should be in or from Mauritius;
• The company must, at all times, have a minimum of two directors resident in Mauritius;
• All board meetings must be held and chaired from Mauritius; and
• The company’s principal bank account must be held in Mauritius.
In addition there are other requirements and we shall ensure that the GBL company is in compliance.