All founders and investors who incorporate in Mauritius face the same decision tree after about one week: GBC or Authorized Company? They have been set up for foreign trade; they belong to the same regulatory body; yet the result differs in taxes, eligibility for treaties, and operating expenses. Selecting the wrong vehicle is the number one mistake made in Mauritius – and it’s a costly one to correct. This guide provides a comparison between the two.
Two Structures, One Decision
The current structure has been in effect since 1 January 2019, when Mauritius restructured its global business sector to comply with OECD requirements. The old GBC1 became the current Global Business Company (GBC). The GBC2 structure was discontinued; its duties have been taken up by the new Authorised Company (AC). The licenses were transferred to AC, with the expiry date being 30 June 2021. Officially the GBC license is called the Global Business License (GBL).
The phrase that newcomers tend to use when they look for information about Mauritius company formation for offshore purposes is “Mauritius offshore company”. It is misleading, but in a useful way, as the country doesn’t offer the same level of confidentiality anymore and now competes on other grounds. Both structures are regulated by the Financial Services Commission (FSC), both of them are meant to be used for conducting business activities mostly abroad and the choice of one or another form of entity for incorporation in Mauritius starts the process of deciding about everything else. Below is the description of the two vehicles and the analysis of their features.
What Each Structure Is
Global Business Company (GBC)
A Global Business Company in Mauritius is a tax-resident entity holding a full FSC licence. It exists for one central purpose: giving an international structure access to the island’s network of more than 45 Double Taxation Agreements (DTAs). Because the GBC is resident, the Mauritius Revenue Authority (MRA) can issue it a Tax Residence Certificate (TRC) – the key that unlocks reduced withholding rates in the countries where the company invests.
The tax side is covered in detail in our guide to the tax benefits of Mauritius; in short, the headline corporate rate is 15%, and an 80% partial exemption on qualifying foreign income brings the effective rate on that income to about 3%. The price of residency is real presence: a GBC must be managed and controlled from Mauritius.
Authorised Company (AC)
An Authorised Company is the opposite. The company is incorporated in Mauritius, but its place of management is located elsewhere, and the company’s beneficial owners are primarily non-Mauritians. As far as taxation is concerned, the AC is a non-resident entity, which means that the MRA levies tax on the income sourced from Mauritius, which an ordinary AC lacks.
In fact, such clarity comes with a sharp sting, which needs to be addressed directly. No taxation in Mauritius does not equate to no taxation elsewhere, since the company will typically be subject to taxation wherever it is managed and will have no access to the DTA regime or TRC. The AC is required to appoint a registered agent (licensed management company) and make a filing with the MRA within six months after the company’s fiscal year-end.
GBC vs Authorised Company: Six Differences That Matter
Six criteria decide the choice in practice – tax status, treaties, substance, supervision, permitted activity and budget.
1. Tax Residency and Effective Rates
The GBC pays 15% on chargeable profit, reduced to roughly 3% on qualifying foreign income through the partial exemption regime: foreign dividends, interest and a defined set of activities. The AC pays nothing in Mauritius on foreign income, because Mauritius makes no claim on a non-resident’s foreign earnings.
Read those numbers slowly rather than quickly. The GBC’s 3% is a final, defensible rate inside a treaty framework. The AC’s 0% is a blank space that another jurisdiction – usually the one where its managers sit – is entitled to fill. Which number wins depends entirely on what happens outside Mauritius.
2. Access to Double Taxation Agreements
This is the dividing line that settles most cases. A GBC with a TRC claims treaty relief at source: dividends, interest and royalties flowing from India, South Africa, China or some forty other partner states arrive with reduced or zero withholding. On a portfolio producing steady distributions, treaty savings routinely exceed everything the GBC costs to run.
The AC stands outside this system. No residency, no certificate, no relief – a distribution from a treaty country reaches an AC at the full domestic withholding rate. For pure trading flows with no cross-border investment income, that may cost nothing at all. For investment flows, it usually costs more than the AC saves.
3. Substance Requirements
The substance requirements in Mauritius apply asymmetrically. A GBC must show core income-generating activity in or from the island, at least two resident directors, a local registered office, administration by a licensed management company and audited accounts. The Finance Act 2025 tightened the reporting around all of this, so the bar keeps moving up, not down.
An AC needs far less: a registered agent, basic records, an annual return. The catch repeats the tax logic – light substance in Mauritius means the company’s real substance sits wherever it is managed from, and that is where questions about its tax home will eventually be asked.
4. Licensing, Supervision and Reporting
A GBC goes through full FSC licensing: a detailed business plan, fit-and-proper checks on directors and beneficial owners, ongoing supervision with annual compliance certificates, and audited financial statements filed every year. The process is slower and the scrutiny permanent – which is precisely why banks and counterparties treat a GBC as a serious entity.
An AC is registered rather than licensed. The application is shorter, the ongoing obligations lighter, and there is no annual substance reporting to the FSC. Both vehicles file annual returns with the Registrar of Companies, and both disclose beneficial ownership to the authorities – confidentiality from the public register is not exemption from regulation.
5. Permitted and Restricted Activities
A GBC can conduct nearly any lawful activity, including regulated financial services under the appropriate permissions: fund management, treasury, leasing, investment dealing. Within limits set by law, it may even transact with Mauritian residents.
The AC’s field is narrower. It cannot trade inside Mauritius, and the Financial Services Act closes the door on:
- banking and other financial services
- holding or managing collective investment schemes and funds
- nominee and trusteeship services
- providing registered-office, directorship or corporate services to other companies
What remains – international trading, consultancy, holding assets and intellectual property – still covers most simple cross-border setups.
6. Setup and Annual Costs
Market ranges rather than quotes, worth confirming case by case. A GBC typically costs around USD 5,000-12,000 to establish in year one, with annual maintenance from roughly USD 8,000 once substance, audit and administration are counted. An AC usually forms for USD 2,000-5,000 and runs from about USD 3,000 a year.
The gap looks decisive until treaty math enters. One reduced-withholding dividend from a treaty country can repay a year of GBC expenses; a structure with no such flows is paying for substance it never uses. The cost comparison only makes sense next to the income map.
Which Structure Fits Which Scenario
1. When the GBC Is Worth Its Cost
Three profiles keep choosing the GBC. First, a holding company in Mauritius for operating businesses in Africa or Asia, where dividends and exit proceeds pass through treaty protection. Second, investment funds and their managers, for whom FSC licensing is not a burden but the product itself. Third, groups that need a TRC to satisfy a foreign tax authority or a bank’s onboarding team.
The common thread is inbound investment income or the need for recognized residency. Wherever withholding tax is being paid abroad, a GBC has a concrete number to earn back every year – and that number, not the effective 3%, is what usually justifies the structure.
2. When the Authorised Company Is Enough
The AC fits flows that never touch treaty benefits. An international trading company invoicing between third countries. A vehicle holding intellectual property or a single asset with no distribution stream. A consultancy billing clients from a neutral base. In these cases the classic Mauritius offshore company search intent – a simple, regulated, inexpensive entity – is answered by the AC, minus the anonymity the phrase once implied.
Two honest tests before choosing it: is there any cross-border investment income that treaties would protect, and is the owner comfortable that the company will likely be taxable where its management sits? Two clear answers, and the AC saves real money.
3. When Neither Fits: the Domestic Company and Other Routes
An operation aimed at the Mauritian market – a hotel, an agency serving local clients, a manufacturer – belongs in a Domestic Company, taxed at standard local rates and free of global business licensing. Family wealth spanning generations may sit better in a trust or a foundation, sometimes alongside a GBC rather than instead of one.
A decade of restructurings teaches one lesson: entities chosen by price alone migrate later, at several times the saved amount. Formation is cheap to plan and expensive to redo.
How the Setup Works
The sequence is similar for both vehicles; the depth differs. A realistic path through company formation in Mauritius:
- Define the activity, the income flows and the target markets – this dictates the vehicle.
- Reserve the name with the Registrar of Companies.
- Prepare the file: passports and proof of address for shareholders and beneficial owners, an ownership chart, a business plan (detailed for a GBC, brief for an AC).
- Submit through a licensed management company – the GBC to the FSC for licensing, the AC for registration and appointment of the registered agent.
- Open the bank account; the compliance review at Mauritian banks commonly takes four to eight weeks.
- Register with the MRA and set the accounting calendar.
Documents not in English or French need certified translations, and gaps in the beneficial-ownership chart are the most frequent cause of resubmission – both worth fixing before step four. An AC is often operational within two to three weeks plus banking. A GBC realistically takes one to three months end to end, with the FSC review as the pacing step.
How MGM Helps You Choose and Set Up
MGM is a licensed management company in Mauritius, which means both roles in this article are ours by design: administrator for a GBC and registered agent for an AC. Whether the plan is a trading vehicle or a holding company in Mauritius, the work starts before incorporation – mapping where the income arises, which treaties apply and what substance will cost. That map, not a feature table, is what picks the structure.
After the choice, MGM runs the full cycle: FSC licensing or AC registration, resident directors and a local office for GBC substance, accounting, audit coordination and every filing with the FSC and the MRA. Clients with an existing entity get the same work in reverse: a review of whether the current vehicle still matches the flows, what the Finance Act 2025 changed for its substance and reporting, and a cost conversion plan where an upgrade makes sense.
Contact the MGM team for a structuring consultation
One working session with your income map is usually enough to name the right vehicle and price it precisely.
Frequently Asked Questions
Can an AC Be Converted to a GBC Later?
Yes – the upgrade path is well trodden. The company applies to the FSC for a Global Business Licence, builds the required substance (resident directors, local administration, audit) and, once licensed, obtains its TRC from the MRA. Plan for the same review timeline as a fresh GBC application, and note that treaty benefits start from residency, not retroactively. Many groups deliberately start light and convert when investment income appears; the reverse move, unwinding a GBC that was never needed, is messier and costlier.
Does an AC Pay Tax Anywhere?
Almost always, yes – somewhere. An Authorised Company in Mauritius pays nothing locally on foreign income because the vehicle is non-resident; the jurisdiction where the company is actually managed and controlled generally gains the right to tax it under its own rules. Owners who treat the AC as globally tax-free discover this during a home-country audit, at the worst possible price. The right question at the design stage is not “how do we pay nothing” but “where will this entity be resident, and is that outcome acceptable” – answered with an adviser in that jurisdiction.
Which Is Faster to Open?
The AC, comfortably. Registration through a management company typically completes within two to three weeks once documents are ready, against one to three months for a GBC with FSC licensing. Banking is the equalizer: account opening takes four to eight weeks for either vehicle, and it often becomes the true critical path. Preparing shareholder documents, the ownership chart and the activity description before applying shortens both tracks more than anything else – and the banking file is best started in parallel with the application, not after it.
Does a GBC Always Get the 3% Rate?
No. The 3% applies to qualifying foreign income under the partial exemption – foreign dividends, interest and a defined list of activities – and only while the substance requirements in Mauritius are genuinely met. Non-qualifying income is taxed at the standard 15%, and a company that lets its substance slip risks both the exemption and its treaty position. The rate is an outcome of maintained compliance, not a feature switched on at incorporation – and the MRA does test the exemption at audit.
Can Either Structure Open a Mauritius Bank Account?
Both can, and both pass the same know-your-customer review. In practice a licensed, tax-resident GBC tends to move through onboarding more smoothly, since banks read the FSC licence as pre-vetting; an AC compensates with a clean file and a clear activity description. A Global Business Company in Mauritius also finds it easier to open accounts abroad, where the TRC and audited statements answer most correspondent-bank questions before they are asked.