Mauritius Company Formation

Two bodies matter in Mauritius. The Registrar of Companies, in the Corporate and Business Registration Department (CBRD), incorporates companies under the Companies Act 2001. The Financial Services Commission (FSC) licenses global business under the Financial Services Act 2007, Part X. A Global Business Company (GBC) is a company incorporated under the Companies Act that also holds a Global Business Licence from the FSC. Everything that makes a GBC different from an ordinary company comes from that licence.

The honest starting point is that a GBC is no longer the cheap offshore company it was. Until 31 December 2018 Mauritius issued Category 1 and Category 2 Global Business Licences. The MRA states that both were abolished with effect from 1 January 2019, with grandfathering to 30 June 2021 for licences issued before 16 October 2017. What exists now is one category of GBC, which must carry out its core income-generating activities in Mauritius, be managed and controlled from Mauritius and be administered by a licensed management company. It has Mauritius-resident directors, a Mauritius bank account and audited accounts prepared in Mauritius. Those rules are set out under how the post-2019 regime works.

There is a lighter option, the Authorised Company, which is run from outside Mauritius and cannot do banking, funds, financial services, corporate services or trusteeship. And there is the ordinary domestic company under the Companies Act, which is a normal Mauritius taxpayer with a resident director and not an offshore vehicle at all. The three are compared in the table below. Which one fits depends on where the real decisions, staff and money sit.

An application for a GBC can only go through a management company, certified by a law practitioner. We are a facilitator, not a law firm or a regulator: we coordinate the file with a licensed management company and Mauritius counsel, tell you what the FSC and the Registrar will ask for, and confirm the points the public sources do not settle before anything is submitted. If you are still choosing a jurisdiction, the company formation hub sets them side by side, and the pages for the BVI, Seychelles and Cayman Islands cover other offshore options.

Sources and gaps. The Companies Act references are to the consolidated text on the Registrar's site dated 31 August 2026. The Financial Services Act was read on a Stock Exchange of Mauritius copy marked for information only, with amendments listed up to Act 3 of 2026. The FSC's own website, its fee schedule, its Rules and its guidance were not accessible to us when we checked, so every FSC-specific item below is marked as confirmed in writing, not stated as a number. We re-read the current text before any filing.

Not in the old sense. The Category 1 and Category 2 licences were abolished with effect from 1 January 2019, and the 80% deemed foreign tax credit went with them, both with grandfathering to 30 June 2021 for licences issued before 16 October 2017 (see the MRA's international taxation page). Section 71 of the Financial Services Act was replaced from 1 January 2019. Today a GBC is a licensed, tax-resident company whose licence is conditional on what it does in Mauritius.

Under section 71(3), a Global Business Licence holder must at all times carry out its core income-generating activities in or from Mauritius, be managed and controlled from Mauritius and be administered by a management company. In deciding whether the company is managed and controlled from Mauritius, the FSC has regard to five matters, listed at the end of this section.

There is a wording point a careful reader should know. The Act frames the five items as matters the FSC 'shall have regard to'. The Registrar's own page states them flatly: a GBC must have at least two resident directors, must keep its principal bank account in Mauritius and must be administered by a management company. We treat all of them as mandatory and plan the structure that way. The Finance Act 2025 tightened the director test by adding 'at all times' and added the 7-day notice of director changes, so the direction of travel is firmer, not looser.

The Authorised Company is the lighter route, with real limits: central management and control outside Mauritius, a registered agent that is a management company, no banking, funds, financial services, corporate services or trusteeship, and an annual financial summary to the FSC within six months of year end. Under the Income Tax Act it is treated as non-resident if it is centrally managed and controlled outside Mauritius, but it still files a return. We do not assume treaty benefits for it: that is a point for Mauritius counsel to confirm, not one the public sources settle.

Doing business that needs a Global Business Licence without one is an offence, with a fine of up to Rs 1,000,000 (section 71(5)). The FSC may also direct a licence holder to cease business or take remedial action where it breaches the FSC Rules or guidelines (section 71(4)). The FSC can refuse an application for an activity that is unlawful, contrary to the public interest or that may harm the good repute of Mauritius as a financial centre (section 72(4)).

The corporate income tax rate is 15%, per the MRA's corporate taxation page and the Income Tax Act (First Schedule, Part IV). Under Income Tax Act section 73 a company is resident if it is incorporated in Mauritius or centrally managed and controlled there, and a GBC is a resident company.

The headline for a GBC is a partial exemption. The Act exempts 80% of certain listed income: foreign dividends, interest earned by a company that is not a bank or other financial business, the profit of a foreign permanent establishment, and income of collective investment schemes and some managers and lessors, among others. It is conditional and it is a list. The MRA states the conditions as three: the company carries out its core income-generating activities in Mauritius, employs directly or indirectly an adequate number of suitably qualified people to carry them out, and incurs a minimum expenditure proportionate to the level of activities (Income Tax Regulations 1996, regulation 23D(2)). Foreign dividends carry two more conditions: the dividend must not have been deducted in the source country, and the prescribed substance conditions must be met. Income that is not on the list, or that does not meet the conditions, is taxed at 15%. We therefore do not quote an effective rate: it depends on which income qualifies.

The Privy Council's judgment in Alteo Energy Ltd v Director-General MRA ([2026] UKPC 27, 30 June 2026) held that 'core' refers to the activities that generate the exempt type of income, and the condition is met if they take place in Mauritius. It does not require lending to be the company's core business. The staff and expenditure conditions in the regulations still apply. A foreign tax credit exists under the Income Tax (Foreign Tax Credit) Regulations 1996, but the old 80% deemed credit is gone.

Treaties: the MRA's treaty page lists 45 treaties, with seven more awaiting ratification. Treaty benefits depend on the treaty in question and on substance, and we do not quote rates.

Limits. The Mauritius rule says nothing about tax at home. The owner's tax residence is tested separately, and the company's residence does not move it. Mauritius has its own controlled foreign company rule, which is a different thing from the CFC and controlled-company rules of the owner's country, and many countries tax a company managed from their territory. Mauritius also applies a Domestic Minimum Top-up Tax from fiscal years ending on or after 1 January 2025, but only to members of in-scope groups with consolidated revenue of EUR 750m. We do not give tax advice and we do not say what your outcome will be: take advice where the owners and decision-makers live before you commit.

The yearly duties follow. They are the reason the page calls a GBC substance-heavy.

A GBC does, and the substance is the licence. In the statutes we read we found no separate economic substance act with a relevant-activities list and a yearly notification of the kind the BVI and Cayman Islands have. Substance sits in two places: section 71(3) of the Financial Services Act, covered above, and regulation 23D of the Income Tax Regulations 1996 for the partial exemption. The 'sufficient calibre' wording matters: the two resident directors have to decide, not sign. The Act classes directorship and nominee services as business that needs a management licence, so any nominee director we arrange for you comes through a licensed management company.

For some income types the regulations define what 'core income-generating activities' means. For interest, regulation 23D(2)(b) names agreeing funding terms, setting the terms and duration of any financing, monitoring and revising agreements, and managing risks. For a trading, services or intellectual-property company we found no published list in the regulations. The FSC circulars and guidance that would fill the gap were not accessible to us, so we do not describe the FSC's expectation as a fact. We confirm it in writing against the current FSC text and your facts before you commit.

Whether the FSC runs a separate substance questionnaire or annual substance return, we could not confirm. The reporting we can source is the 7-day notice of director changes, the annual tax return and the audit in Mauritius. A company that cannot meet the section 71(3) conditions risks a cease-or-remedy direction from the FSC and lapse of its licence if the annual fee is unpaid. A company that cannot meet the regulation 23D conditions loses the partial exemption on the income concerned.

We do not state the current EU or FATF status of Mauritius on this page. The Mauritius government's investment portal records that FATF placed the country on its grey list in February 2020 and removed it on 21 October 2021, and that the EU removed it from its list of high-risk third countries in early 2022 (the portal's two pages give slightly different dates). We could not open the Council of the EU and FATF pages themselves, so current status on both lists is something we confirm before filing, not something this page asserts. Sources: the portal's pages on the EU removal and the AML overview.

More than the marketing suggests. Any document on the Registrar's register can be inspected on payment of the prescribed fee, except the usual residential address where a service address exists (Companies Act section 14(1)). A company must also open certain records for inspection on written notice: the certificate of incorporation, the constitution, the share register, the full names and residential addresses of directors, the registered office and service address, and charge instruments (section 225). In practice a director's residential address and the registered shareholders can be obtained from the company's records. Say that plainly to anyone considering a Mauritius company for privacy.

The beneficial-owner side is separate. The Companies Act requires a company to keep a register of beneficial owners and a written declaration made by the beneficial owner. The threshold is 20% irrespective of the type of share (Companies (Beneficial Owner) (Percentage of Shares) Regulations 2019, GN 237 of 2019), and the register records the full name, usual residential address, ID or passport number, nationality, date of birth and the ownership structure up to the ultimate beneficial owner. Nominee shareholders must be disclosed together with the persons behind them. Details are filed with the Registrar at incorporation, with the annual return and on changes in shareholding.

The Registrar's beneficial-owner register is open to competent authorities and prescribed public authorities (section 11(3)(b), and the Registrar's AML/CFT page), and companies must produce their records to competent authorities on request. We found no provision for public access, so it is not a public register. The consolidated Companies Act on the Registrar's site prints superseded wording and replacement wording side by side for several of these provisions, including the beneficial-owner definition, without marking which is which. For that reason we do not state the fines or the filing deadlines here: a lawyer confirms them on the gazetted text before we file anything.

Mauritius is not a secret jurisdiction. The MRA states that automatic exchange of information under the Common Reporting Standard has applied since 2018 and that FATCA applies. It also states that Mauritius was rated Compliant in the second round of the Global Forum peer review and has information-exchange relationships with some 140 jurisdictions. Information on GBCs is usually obtained from management companies.

A GBC has to. Section 71(3)(b) of the Financial Services Act lists a principal bank account kept in Mauritius at all times among the tests of management and control, and the Registrar repeats it for GBCs. A GBC may also hold a foreign-currency account with a bank and a rupee account for local costs without losing its status as a company conducting business outside Mauritius (section 73(1)). So the account is a legal requirement and, in our timetable, the hardest step, because a bank decides independently of the FSC and the Registrar.

Banks look at who the beneficial owners are, where the company is managed, what it will do and where the money comes from. Providers commonly report that onboarding takes weeks after the licence and often needs verification of the owners in person or by video. We have no verified figure, so we give none. We do not name banks, we do not quote an approval rate and we do not promise an account. The EMI or neobank accounts we discuss for some other structures cannot be assumed to satisfy this rule, because the principal account has to be in Mauritius.

We found no equivalent principal-account requirement for an Authorised Company in the statute text we read. Whether a bank accepts one is still the bank's decision. For payment acceptance and merchant-account questions, our page on high-risk merchant accounts explains what providers ask for and why applications fail.

It is not a cheap offshore company. The Registrar's incorporation fee for a GBC is Rs 3,200, which is a small share of the real cost. The rest is a licensed management company, two resident directors, a Mauritius audit and a Mauritius bank, each a separate service, plus the FSC's own fees. We publish no prices for these and we do not say that any of them is small.