Company Setup
GBC vs Authorised Company in Mauritius (2025 Comparison)
Global Business Corporation or Authorised Company? A side-by-side comparison of tax residency, substance rules, banking and audit obligations under the FSC 2025 rulebook.
Two very different vehicles
Both licences are issued by the Financial Services Commission (FSC), but a GBC is a tax-resident Mauritian entity that can claim treaty benefits, while an Authorised Company (AC) is expressly non-resident for tax purposes and cannot access Mauritius's DTAA network.
Side-by-side comparison
| Feature | GBC | Authorised Company |
|---|---|---|
| Tax residency | Resident | Non-resident |
| Corporate tax | 15% (80% partial exemption on qualifying income → effective 3%) | No Mauritius tax, but must file an annual return of income |
| Treaty access | Yes — full DTAA network | No |
| Substance | 2 resident directors, local bank a/c, local admin, primary bank a/c in Mauritius | Registered agent only |
| Audit | Mandatory | Not required (financial summary filed) |
| Best for | Fund management, holding vehicles claiming treaty relief | Passive foreign asset holding, family offices |
Substance under the FSC 2021 rules (still in force)
- Employ (directly or indirectly) a reasonable number of qualified persons.
- Incur a reasonable level of expenditure proportionate to activities.
- Have a physical office in Mauritius.
- At least 2 resident directors of appropriate calibre.
- Board meetings chaired in Mauritius; minutes kept locally.
Which licence for which strategy?
- Fund manager targeting Indian investments → GBC (treaty relief on capital gains and dividends).
- Family office holding portfolio investments → AC.
- Regional headquarters with staff and P&L in Mauritius → GBC (with GHQ scheme where eligible).
- Passive IP holding for non-EU markets → AC (subject to substance in the operating jurisdiction).
Frequently asked questions
Q. Can an Authorised Company use Mauritius's tax treaties?
No. An Authorised Company is expressly non-resident and cannot claim benefits under Mauritius's Double Taxation Avoidance Agreements.
Q. Do GBCs still get the 3% effective tax rate?
Yes — through the 80% partial exemption on qualifying foreign-source income, subject to meeting the FSC substance rules. Pillar Two/QDMTT may top the effective rate up to 15% for in-scope MNE groups.
Q. Is a GBC required to be audited?
Yes. Every GBC must appoint a Mauritius-licensed auditor and file audited accounts with the FSC and MRA.