Which Mauritian structure should you set up in 2026: GBC (Global Business Company), Authorised Company or Domestic Company? This question comes up in 9 out of 10 discovery calls. And the answer is never just “it depends”, it depends on precise, measurable criteria: where your revenue comes from, where your clients are, which tax treaties you need to activate, what substance you’re willing to put in place, and your annual budget.
This guide is an operational decision matrix: we define each structure, compare them line by line, stress-test them against 4 typical entrepreneur profiles, and give you our decision tree at the end. No “consult your accountant” without saying anything else: real numbers, real cases, real sources.
YMYL disclaimer: this content is informational and not personalised advice. The right structure for your project depends on your global tax situation (residence, type of activity, clients, applicable treaties). Our firm supports this decision with certified Mauritian accounting and legal partners (MIPA, FSC).
In short: the 3 structures in one sentence
- Domestic Company → “classic” Mauritian company, designed to do business in Mauritius and with treaty partners. 15% corporate tax, full access to 45+ tax treaties. No FSC licence required.
- Global Business Company (GBC) → company under FSC licence, dedicated to international activities (clients/revenues mainly outside Mauritius). 15% corporate tax with Partial Exemption mechanism reducing the effective rate to ~3% on certain income. Treaty access conditional on economic substance.
- Authorised Company → company not tax-resident in Mauritius, designed for holdings and 100%-non-Mauritius activities. 0% tax in Mauritius (but taxable in the country of effective management). No access to Mauritian tax treaties.
The right choice depends on three questions:
- Are your clients mainly in Mauritius or international?
- Do you need access to Mauritian tax treaties (notably with France)?
- What level of economic substance are you willing to put in place?
1. Domestic Company: the “classic” structure
Definition
A company set up under the Mauritius Companies Act 2001, without any special FSC licence. It can operate freely in Mauritius and with any jurisdiction. Its tax regime is the standard one.
Tax regime
- Corporate tax: 15% (flat rate, no progressivity)
- No capital gains tax on movables
- No withholding tax on outbound dividends (to non-resident shareholders)
- 15% VAT if turnover > 6M MUR (~€120,000)
- Automatic access to 45+ tax treaties of Mauritius (France, Belgium, Switzerland, UK, India, South Africa, etc.)
Required substance
Minimal: a registered office in Mauritius (often provided by the firm), at least one Mauritius-resident director, accounting kept in Mauritius. No mandatory employee if the activity doesn’t really require it.
For whom?
- Entrepreneur physically relocating to Mauritius wanting to serve a mix of local + international clients
- Consulting, services, freelance, e-commerce, agency activities
- Anyone wanting to benefit from tax treaties (notably France-Mauritius to repatriate dividends)
- Budget: €3,600/year (our standard offer) for full management
Advantages
- Simplicity: no FSC licence to apply for
- Automatic treaty access
- 15% flat corporate tax (vs 25-33% in France, Belgium, Germany)
- Minimal acceptable substance
- Quick setup: ~3-5 weeks
Limitations
- 15% effective corporate tax rate (vs ~3% for GBC on certain income)
- No additional optimisation via Partial Exemption
- Not suited for pure holding activities or purely international structures
2. Global Business Company (GBC): the optimised international structure
Definition
The GBC is a company set up under the Companies Act 2001 with a Global Business Licence issued by the FSC (Financial Services Commission). It’s designed for businesses whose activity and revenues are mainly outside Mauritius.
Tax regime
- Corporate tax: 15% (same nominal rate as Domestic)
- But Partial Exemption mechanism: 80% exemption on certain income → effective rate ~3%
- Eligible income: foreign dividends (subject to conditions), foreign interest, ship/aircraft leasing income, royalties (under strict conditions since 2019), collective asset management income, etc.
- No outbound withholding tax
- Treaty access conditional on substance (see below)
Economic substance: non-negotiable
Since 2019 and the post-BEPS FSC tightening, a GBC without substance loses its preferential tax regime and treaty access. Requirements:
- At least 2 Mauritius tax-resident directors (can include the founder if they become resident)
- Minimum operating expenditure in Mauritius (proportional to activity, in practice often > USD 12,000/year minimum)
- Board meetings held physically in Mauritius (with supporting minutes)
- Main bank accounts opened in Mauritius
- Employees or service equivalents in Mauritius if activity justifies
- Physical office or qualified domiciliation
This is what the FSC calls “core income-generating activities” (CIGA), the key functions generating income must actually be performed in Mauritius.
For whom?
- 100% or mainly international activity with clients outside Mauritius
- International holding (participations in multiple countries)
- Financial activity, asset management, IP licensing
- Sufficient revenue volume to absorb economic substance (in practice: revenue > €200k/year for positive ROI vs Domestic)
- Founder willing to transfer tax residence OR to hire a qualified local team
Advantages
- Effective corporate tax rate down to ~3% on eligible income
- International image + treaty access (subject to substance)
- Status recognised on financial markets (banks, counterparties, investors)
Limitations
- Higher annual costs: FSC licence ~USD 1,800/year + substance (resident directors, premises, expenditure) → total ~USD 8,000-15,000/year minimum
- Setup time: 6-10 weeks (including FSC approval)
- Enhanced compliance: FSC reporting, mandatory audited accounts, annual economic substance test
- Our pricing: €5,600/year (preferential regime offer) for full management, eligibility to validate based on activity
3. Authorised Company: the pure holding
Definition
The Authorised Company is set up in Mauritius but considered non tax-resident in Mauritius. It’s intended for activities exclusively outside Mauritius, with no access to the local market.
Tax regime
- 0% tax in Mauritius (the company is not resident there)
- But taxable in the country of effective management (typically where the founder resides or where the company is actually run)
- NO access to Mauritian tax treaties
- No mandatory audited accounts (but accounting required)
Required substance
Much lighter than a GBC:
- A registered agent in Mauritius
- No mandatory resident director
- No board meeting in Mauritius
For whom?
- Patrimonial holding of a foreign tax resident centralising their participations in a neutral structure
- 100% non-Mauritius activity where treaty access is NOT needed (rare)
- Founder who remains tax-resident elsewhere and just wants a simple, low-cost holding vehicle
Major limitations
- No tax treaties: no optimisation of withholding taxes between countries
- Taxable in country of effective management: if the founder lives in France, the Authorised may be qualified as French tax resident and taxed in France
- Regulatory risk profile: since BEPS, Authorised companies are viewed very critically by European tax administrations (often qualified as “conduits”)
- Less favourable image with international banks
⚠️ Our honest view: in 90% of cases, the Authorised Company is NOT the right choice for a French-speaking entrepreneur. It’s a very specific niche structure. If someone is selling it as your main solution, ask why not a Domestic or GBC.
4. Synthetic comparison table
| Criterion | Domestic Company | GBC (Global Business) | Authorised Company |
|---|---|---|---|
| FSC licence | No | Yes (Global Business Licence) | No (but FSC authorisation required) |
| Mauritius corporate tax | 15% | 15% nominal (~3% effective with Partial Exemption) | 0% |
| Taxable where? | In Mauritius | In Mauritius | In country of effective management |
| Accessible tax treaties | Yes (all) | Yes (subject to substance) | No |
| Outbound withholding tax (dividends) | 0% | 0% | 0% |
| Capital gains on movables | 0% | 0% | 0% |
| 15% VAT | Yes if revenue > 6M MUR | No (international activity) | No |
| Mandatory audited accounts | If thresholds exceeded | Yes (systematic) | No |
| Required resident directors | 1 minimum | 2 minimum tax residents | None |
| Required economic substance | Minimal | Strong (CIGA, expenditure, premises) | Very low |
| Setup time | 3-5 weeks | 6-10 weeks | 2-4 weeks |
| Estimated total annual cost (firm + gov) | ~€3,600-4,500 | ~€5,600-15,000 | ~€2,500-4,000 |
| Typical use | Mauritius-resident entrepreneur, freelance, consulting, e-com | International holding, IP, asset management, non-Mauritius activity | Patrimonial holding of a non-resident |
5. Four entrepreneur profiles, four recommendations
Profile A : relocating consultant
Pierre, 35, strategy consultant. €180k revenue, European and African clients. Transfers his residence to Mauritius.
→ Domestic Company. No need for GBC complexity. Pierre becomes Mauritian resident, his company pays 15% corporate tax in Mauritius, he pays himself a reasonable salary (taxed in Mauritius at modest progressive rates), and outbound dividends face no withholding. Total annual cost ~€3,600. Saving vs French structure: ~€40k/year.
Profile B : international SaaS at €1M revenue
Marc, 38, B2B SaaS founder. €1M revenue, clients in 12 countries, 4 full-remote employees, IP centralised.
→ GBC with real substance. Marc transfers his residence (or hires a local executive director), sets up 2-3 employees in Mauritius for support/finance/admin functions, opens an office. The effective corporate tax rate drops to ~3% on eligible IP licensing income. Annual cost ~€12,000 but massive ROI on €1M revenue.
Profile C : e-commerce operator who lives in France
Sophie, 32, lives in Lyon, runs her e-shop. €250k revenue, European clients, she doesn’t want to relocate.
→ None of the three. Sophie is and remains a French tax resident. Setting up a Mauritius company would either (a) be qualified as a French permanent establishment → taxed in France anyway, or (b) be an abusive structure → PPT triggered, reassessment. Honestly, the right advice for Sophie is to stay in France or consider a genuine relocation.
Profile D : retiree-investor wanting a holding
Jean-Luc, 58, lives in Monaco, sold his business for €8M. Wants to centralise his investments (real estate, private equity, crypto) in a neutral structure.
→ Authorised Company conceivable, BUT careful: Monaco residence must be well established and recognised, otherwise France can reclassify. In this specific case, an Authorised truly serves as a simple holding vehicle without operational activity. Cost ~€3,000/year. Alternative: Domestic Company which gives access to tax treaties (useful for international investments).
6. Decision tree (in 4 questions)
Q1 : Are you (or will you become) a Mauritian tax resident?
- ✅ Yes → continue
- ❌ No → STOP. Before anything else, address your residence. Without effective Mauritius residence, you risk permanent establishment + abuse of law in your current country. See our expatriation article.
Q2 : Is your revenue / are your clients mainly in Mauritius or in treaty countries (France, etc.)?
- ✅ Yes (mix local + international) → Domestic Company.
- ❌ No, 100% international → continue.
Q3 : Are you ready to put in place real economic substance in Mauritius (2 resident directors, operational expenditure, board meetings, premises)?
- ✅ Yes → GBC. You benefit from the ~3% effective rate on eligible income.
- ❌ No, lacking capacity or volume → continue.
Q4 : Are you a tax resident of a country that won’t reclassify the structure (Monaco, UAE, etc.) and do you accept losing access to Mauritian tax treaties?
- ✅ Yes → Authorised Company possible.
- ❌ No → fall back to Domestic (with adaptation) or drop the Mauritius project.
7. Classic pitfalls to avoid
- Choosing a GBC for the ~3% rate without substance → FSC refuses licence renewal, the founder’s country reclassifies, reassessment.
- Thinking an Authorised avoids tax in France → if you run the company from France, it’s a French tax resident. The “0% in Mauritius” is just marketing bait in that case.
- Underestimating GBC annual costs → FSC licence, directors, mandatory audit, premises: €8-15k/year minimum. On €100k revenue, ROI is null.
- Making the wrong choice at the start → migrating from a Domestic to a GBC (or vice versa) is heavy and costly. Take 2 hours with a tax specialist to decide properly BEFORE.
- Confusing Authorised Company with old structures: there’s historical terminology around the now-abolished GBC2 (2019). In 2026, the only active structures are: Domestic, GBC (ex-GBC1), and Authorised Company.
8. Our method at CAP Maurice
During the discovery call, we ask 7 questions that suffice to determine the right structure:
- Where will you physically live for the next 12 months?
- Where do (and will) your clients come from?
- Real or projected 12-month revenue?
- Do you have existing participations or IP to contribute?
- Are you tax resident of a country with a France-Mauritius treaty (or equivalent)?
- Can you hire locally in Mauritius?
- What annual budget are you willing to allocate to the structure?
From these answers, we tell you in 30 minutes which structure fits, and what it costs all-inclusive. Book a discovery call, free, no commitment.
Sources and official references
- Mauritius Companies Act 2001: supremecourt.govmu.org
- Mauritius Income Tax Act: mra.mu/legislations
- Financial Services Commission (FSC), Global Business Licence rules: fscmauritius.org
- Partial Exemption regime (Income Tax Act, Second Schedule): MRA
- Substance requirements (CIGA) post-2019: FSC Guidance Notes
- OECD BEPS Action 5 (substantial activity requirements): oecd.org/tax/beps
- Multilateral Instrument (BEPS Action 6) applied to the France-Mauritius treaty: see our France-Mauritius Tax Treaty 2026 guide
Article written by Quentin, founder of CAP Maurice. Last updated 26 May 2026. To assess which structure fits your project, book a free discovery call.
