Mauritius Offshore GBC Corporate Tax Calculator
Simulate corporate tax liabilities for Global Business Companies (GBC) and Authorized Companies (AC) in the Mauritius IFC: model the 80% Partial Exemption Regime (effective 3.0% rate), Foreign Tax Credits (FTC), CIGA substance compliance, and dividend repatriation in USD and MUR.
⚡ Offshore Corporate Structure Presets
GBC Fiscal Parameters
USD ($) BaseNet global earnings before corporate income tax assessment.
Under Income Tax Regulations 2018, qualified foreign income qualifies for the 80% exemption.
Creditable against Mauritius 15% headline tax when electing Foreign Tax Credit regime.
Official Bank of Mauritius indicative conversion rate.
Mauritius Tax Liability & Repatriation Overview
📋 Core Income Generating Activities (CIGA) Compliance
Minimum 2 local resident directors of adequate caliber to exercise management control.
Principal commercial bank account maintained within Mauritius commercial banking sector.
Adequate operational expenditure in Mauritius (typically $12k-$25k/yr depending on activity).
Direct employment or engagement of qualified Management Company (MC) administrators.
Mauritius Corporate Tax Structures: Statutory Comparison Matrix
| Entity Structure | Statutory Basis | Effective CIT | DTAA Access | Withholding Tax |
|---|---|---|---|---|
| Global Business Company (GBC) - Partial Exemption | Income Tax Regs 2018 (Item 1-8) | 3.00% | Yes (45+ Treaties) | 0% (Zero WHT) |
| GBC with Foreign Tax Credit (FTC) | Income Tax Act 1995 (Sec 74) | 0.00% - 15.00% | Yes (Treaty & Unilateral) | 0% (Zero WHT) |
| Authorized Company (AC) | Financial Services Act 2007 (Sec 71A) | 0.00% (Foreign Taxed) | No (Non-Resident) | 0% (Zero WHT) |
| Domestic Resident Enterprise | Income Tax Act 1995 (Sec 4) | 15.00% + 2% CSR | Yes | 0% Dividends |
Comprehensive Regulatory & Tax Guide for Mauritius GBCs
1. The 80% Partial Exemption Regime
Under the Mauritius Income Tax Act and statutory amendments aligning with the OECD Base Erosion and Profit Shifting (BEPS) Action 5 requirements, Mauritius abolished previous ring-fenced offshore regimes and introduced a non-discriminatory 80% Partial Exemption Regime available to all resident entities meeting statutory criteria.
- Foreign Dividends: Foreign dividends received by a Mauritius resident company qualify for an 80% exemption, provided they are not allowed as a tax deduction in the country of origin.
- Foreign Interest Income: Interest derived from loans granted outside Mauritius is eligible for an 80% partial tax shield.
- Ship & Aircraft Leasing: Income from operating leases on commercial maritime vessels and aircraft.
- Permanent Establishment (PE) Profits: Profits attributable to a permanent establishment situated in an overseas jurisdiction.
2. Double Taxation Treaty Network & Zero WHT
Mauritius possesses an extensive network of over 45 bilateral Double Taxation Avoidance Agreements (DTAAs), providing substantial tax efficiency for cross-border investments across Africa, Asia, and Europe.
- Zero Outbound Withholding: No withholding tax on dividends paid to domestic or overseas corporate and individual shareholders.
- Zero Capital Gains Tax: Capital gains realized on the sale of shares, bonds, or digital assets are 100% exempt from Mauritian taxation.
- No Exchange Controls: Complete freedom to transfer capital, profits, and management fees into and out of Mauritius in USD, EUR, GBP, or ZAR.
- Fast-Track Dispute Resolution: Direct recourse to the Privy Council of the United Kingdom as the ultimate appellate court.
Frequently Asked Questions (FAQ)
How does the 80% Partial Exemption regime apply to Mauritius GBCs?
Under the Income Tax Regulations 2018, a Global Business Company (GBC) licensed by the Financial Services Commission (FSC) qualifies for an 80% exemption on specified income streams (foreign dividends, interest, royalties, foreign branch profits, and ship leasing). This reduces the effective corporate income tax from the 15% headline rate down to an effective rate of 3.0%.
What are the Core Income Generating Activities (CIGA) requirements?
To claim the 80% partial exemption, a GBC must demonstrate economic substance in Mauritius: it must carry out core income-generating activities locally, employ directly or indirectly an adequate number of qualified persons, and incur an adequate amount of annual operational expenditure in Mauritius (typically USD 12,000 to USD 50,000 depending on activity).
What is the tax status of an Authorized Company (AC) in Mauritius?
An Authorized Company is incorporated in Mauritius but conducts business and has its central management and control outside of Mauritius. It is treated as non-resident for tax purposes and pays 0% corporate tax in Mauritius, but cannot access Mauritius's Double Taxation Avoidance Agreements (DTAAs).
Can a GBC utilize Foreign Tax Credits (FTC) instead of partial exemption?
Yes. A GBC can elect to claim credit for foreign taxes paid abroad against its 15% Mauritius tax liability up to the full amount of Mauritius tax due, provided verifiable proof of withholding or foreign corporate tax payment is submitted to the MRA.
Does Mauritius levy withholding tax on dividends paid to foreign shareholders?
No. Mauritius levies 0% withholding tax on outbound dividend payments, interest, and royalties paid to non-residents, and 0% capital gains tax upon the disposal of equity shares or assets.