Company Setup
Setting Up a Variable Capital Company (VCC) in Mauritius
The VCC is Mauritius's answer to the Cayman SPC and Singapore VCC. Here's how to set one up, the sub-fund architecture, and the tax and regulatory treatment in 2025.
What is a VCC?
A Variable Capital Company (VCC) is a corporate structure introduced by the VCC Act 2022 that allows a single legal entity to house multiple sub-funds, each with segregated assets and liabilities. It is Mauritius's flagship response to the Singapore VCC and the Cayman Segregated Portfolio Company (SPC).
Key features
- Single legal entity, multiple sub-funds with statutory ring-fencing.
- Sub-funds can be open- or closed-ended and have different investment strategies.
- Capital can be freely issued and redeemed at NAV.
- Managed by a FSC-licensed CIS Manager or self-managed under conditions.
- Board of directors sits at umbrella level; sub-funds share it.
Tax position
| Item | Treatment |
|---|---|
| Corporate tax | 15% at umbrella level with 80% partial exemption on qualifying foreign-source income → effective 3% |
| Sub-fund losses | Ring-fenced to that sub-fund |
| Dividends / redemptions to investors | No Mauritius withholding tax |
| Treaty access | Yes via GBC status at umbrella level |
Set-up steps
- Reserve name and apply to FSC for the VCC + CIS licence.
- Appoint a CIS Manager, custodian, administrator and MLRO.
- File constitution and offering document.
- Register each sub-fund with the FSC before launch.
- Open umbrella and sub-fund bank accounts (Mauritius-licensed bank).
Frequently asked questions
Q. How is a VCC different from a GBC?
A GBC is a single legal entity with one balance sheet. A VCC is a corporate umbrella that can hold many sub-funds, each with segregated assets and liabilities.
Q. Can a VCC redomicile from Cayman?
Yes. The VCC Act allows inward migration from other jurisdictions, subject to FSC approval and CIS licensing.