Authorised Companies (AC) are non-resident for tax purposes in Mauritius.
A Global Business Corporation (GBC) is liable to taxes at the rate of 15%. However upon satisfying the conditions relating to the substance* of its activities in an Off Shore Jurisdiction s, the GBC will be entitled to 80% tax exemption on:
- Profits attributable to a permanent establishment which the GBC has in a foreign country;
- Foreign source dividend income provided the dividend has not been allowed as a deduction in the country of source;
- Foreign source Interest income.
- Foreign source income derived by a Collective Investment Scheme (CIS), Closed End Fund, CIS Manager, CIS Administrator, Investment Advisor or Asset Manager licensed or approved by the FSC.
When a company not resident in an Off Shore Jurisdiction, which pays a dividend, has itself received a dividend from another company not resident in an Off Shore Jurisdiction (a ‘secondary dividend’) of which it owns either directly or indirectly at least 5% of the issued share capital, such dividend will be allowable as a foreign tax credit and an underlying foreign tax credit will also be available. However, no Foreign Tax Credit are allowed on Foreign Source income* where the 80% exemption has been claimed by the GBC.
There is no capital gains tax, and no withholding tax on payment of dividends, interests or royalties paid to non-Residents.
*Foreign Source income is defined as “ income which is not derived from Mauritius and includes in the case of a corporation holding a GBC licence, income derived from its transactions with non-residents or corporations holding a Global Business Licence under the Financial Services Act.
