A 15% headline rate, an 80% partial exemption on qualifying foreign income and 45+ tax treaties — for structures that carry real substance.
Mauritius is the jurisdiction of choice for funds and holding companies investing into Africa and India. Corporate tax is a flat 15%, an 80% partial exemption brings the effective rate on qualifying foreign-source income down to 3%, there is no capital gains tax, and no withholding tax on dividends paid out.
What makes it work is the treaty network — and what protects it is substance. A Global Business Company keeps treaty access only if it is genuinely run from Mauritius: resident directors, board meetings on the island, a local bank account and audited accounts. We set it up on that basis, or recommend a simpler vehicle where treaty access is not the point.
Mauritius is an island republic in the Indian Ocean, roughly 2,000 km off the east coast of Africa. It runs a hybrid legal system — French civil law with English common-law procedure — works in English and French, and regulates its financial sector through the Financial Services Commission. Its position was built on a wide treaty network, and today it is held by substance rather than secrecy.
Three vehicles are in common use, and what separates them is tax residence and access to those treaties.
Licensed by the FSC, tax-resident in Mauritius and the only route to the treaty network. It carries real substance: at least two Mauritius-resident directors, board meetings held on the island, a local bank account, a licensed management company and audited accounts. The vehicle for funds, regional holdings and service companies investing into Africa and India.
Registered with the FSC but managed and controlled outside Mauritius, so it is treated as non-resident and is not taxed there. Light on substance and quick to form — but with no access to the treaties, and it still has to be taxed somewhere. The wrong tool whenever treaty relief is the point of the structure.
An ordinary Mauritius company, tax-resident at 15%, for business done in or from Mauritius. The simplest to run: one resident director, a registered office, and VAT registration once turnover passes MUR 3 million.
The annual obligations have the same shape whichever route you take: financial statements and, where required, an audit; a corporate tax return within six months of the financial year end; and for larger companies a 2% Corporate Climate Responsibility levy above MUR 50 million of turnover, plus the Fair Share Contribution running to 30 June 2028. We plan for those before the structure is signed off.
Mauritius usually sits as the treaty layer above an African or Indian investment, with the group operating company in Hong Kong or Singapore. We keep the whole chain consistent.
FSC licensing, incorporation and your corporate documents through a licensed management company.
GBC, Authorised Company or domestic company — matched to where treaty access actually matters.
Resident directors, board meetings, registered office and the records that keep treaty access defensible.
Bookkeeping, audited financial statements and the annual corporate tax return.
Mauritius bank accounts, and Hong Kong or Singapore accounts for the operating company.
Funds and holding companies investing into Africa and India, and groups that need a treaty layer above an operating company.
A short call to recommend the structure, jurisdiction and bank for your case — fees quoted per case.
