Corporate tax rate: 15% standard (approximately 3% effective for GBL with substance)
Double taxation treaties: 46 (including India, China, France, UK, South Africa)
Minimum directors: 2 resident directors in Mauritius
Annual licence fee: USD 1,950 for GBL
Primary source: Economic Development Board Mauritius (edbmauritius.org)
Mauritius has been Africa's premier financial centre for over 30 years. The Global Business Licence (GBL) is the structure that private equity funds, venture capital firms, family offices and multinational companies use to hold and manage investments across Africa and Asia. Here is what the EDB actually requires and what has changed since the 2019 substance reforms.
What the GBL is and who uses it
A Global Business Licence company is a Mauritius-incorporated company that conducts business primarily outside Mauritius. It is not a trading company - it is a holding and investment vehicle.
Who uses it:
- Private equity funds investing in African companies
- Venture capital firms with African portfolio companies
- Family offices managing cross-border wealth
- Multinational companies using Mauritius as a regional holding structure
- African entrepreneurs who want a credible international holding structure
What it is not:
- A trading company (for that, you need a domestic Mauritius company)
- A zero-tax structure (the 3% effective rate requires genuine substance)
- A way to avoid Nigerian or other African tax obligations on income earned in those countries
The tax structure - how the 3% effective rate works
Mauritius's standard corporate tax rate is 15%. GBL companies can claim a partial exemption on foreign-sourced income, reducing the effective rate.
The partial exemption: 80% of specified foreign-sourced income is exempt from tax. This means only 20% of that income is taxed at 15%, giving an effective rate of 3%.
Specified foreign-sourced income includes:
- Dividends from foreign subsidiaries
- Interest from foreign sources
- Royalties from foreign sources
- Capital gains from foreign investments (Mauritius has no capital gains tax)
The substance requirement: To claim the partial exemption, the GBL company must meet the substance requirements introduced in 2019. A company that exists only on paper cannot claim the exemption.
The 2019 substance reforms - what changed
Before 2019, Mauritius GBL companies could be pure shell structures with minimal local presence. The 2019 reforms, driven by OECD pressure, changed this.
Current substance requirements:
| Requirement | Detail |
|---|---|
| Resident directors | Minimum 2 directors resident in Mauritius |
| Board meetings | At least 1 board meeting per year held in Mauritius |
| Principal bank account | Must be maintained in Mauritius |
| Accounting records | Must be kept in Mauritius |
| Staff and expenditure | Adequate staff and expenditure in Mauritius |
What this means in practice: You need a registered agent in Mauritius who provides resident directors, a registered office, and administrative services. This costs approximately USD 5,000-15,000/year depending on the level of service.
The treaty network - why it matters
Mauritius has 46 double taxation treaties. For African investors, the most relevant are:
| Country | Dividend withholding tax (with treaty) | Without treaty |
|---|---|---|
| India | 5-10% | 20% |
| South Africa | 5-10% | 20% |
| China | 5% | 10% |
| France | 5-15% | 30% |
| UK | 0-15% | 20% |
| Mozambique | 8% | 20% |
| Rwanda | 0% | 15% |
The practical benefit: If a Mauritius GBL company holds shares in a South African subsidiary, dividends paid from the South African company to the Mauritius holding company are subject to reduced withholding tax under the treaty. Without the treaty, the full withholding tax rate applies.
Setting up a GBL company - the process
Step 1 - Appoint a management company: GBL companies must be administered by a licensed Management Company in Mauritius. The management company provides resident directors, registered office, and compliance services.
Step 2 - Apply for the GBL licence: The management company applies to the Financial Services Commission (FSC) for the GBL licence on your behalf.
Step 3 - Incorporate the company: The company is incorporated under the Companies Act 2001.
Step 4 - Open a bank account: The GBL company must maintain its principal bank account in Mauritius. Major banks include MCB, SBM, and Absa Mauritius.
Timeline: Approximately 4-8 weeks from application to operational company.
Annual costs
| Item | Approximate annual cost |
|---|---|
| GBL licence fee | USD 1,950 |
| Management company fees (resident directors, registered office, compliance) | USD 5,000 - 15,000 |
| Audit fees | USD 2,000 - 5,000 |
| Bank account maintenance | USD 500 - 1,000 |
| Total annual running cost | USD 9,450 - 22,950 |
When a GBL makes sense - and when it does not
Makes sense when:
- You are investing USD 500,000+ across multiple African or Asian markets
- You want to benefit from Mauritius's treaty network to reduce withholding taxes
- You need a credible international holding structure for fundraising
- You are managing a portfolio of investments across multiple jurisdictions
Does not make sense when:
- You are investing in a single country (a local holding company is simpler and cheaper)
- Your investment is below USD 200,000 (annual costs are disproportionate)
- You want a zero-tax structure (Mauritius is low-tax, not zero-tax)
- You cannot meet the substance requirements
Evidence note
All figures sourced from the Economic Development Board Mauritius at https://www.edbmauritius.org/ and the Financial Services Commission Mauritius at https://www.fscmauritius.org/, retrieved October 2026. Tax rates and treaty terms are subject to change. Consult a qualified Mauritius tax adviser and a Nigerian tax adviser before establishing any holding structure.