Structures
Pick the right vehicle, the rest follows.
From Global Business Corporations to Variable Capital Companies, the right Mauritius structure depends on your objectives. We work seamlessly across all of them.
Structures & Incorporation
Financial Services & Licensing
Compare — Structures & Incorporation
Select two structures to compare:
| GBL | AC | Trust | Foundation | LP | PCC | DC | |
|---|---|---|---|---|---|---|---|
Legal personality | Yes (separate legal entity) | Yes (separate legal entity) | No (trustee holds legal title) | Yes (separate legal entity) | Optional (electable at registration) | One entity with statutorily segregated cells | Yes |
Tax residence | Tax-resident in Mauritius | Non-resident (central management outside Mauritius) | Tax treatment depends on residence, source and nature of income. A non-resident trust is generally taxable in Mauritius on chargeable income attributable to Mauritius-source income. Partial exemptions may be available on qualifying income subject to statutory conditions | Tax treatment depends on residence, source and nature of income. A non-resident foundation is generally taxable in Mauritius on chargeable income attributable to Mauritius-source income. Partial exemptions may be available on qualifying income subject to statutory conditions | Generally fiscally transparent for Mauritius income-tax purposes; a resident société holding a GBL may elect to be taxed at company level, subject to the applicable tax rules | GBL regime applies (typically) | Yes (Mauritius) |
Treaty eligibility | Yes — 45+ double-taxation agreements | No | No (trust itself is not a taxable entity) | No (foundation itself is not treaty-eligible) | Depends on entity-level tax residence | Yes, if structured as GBL | Yes, potentially |
Ownership | Majority non-resident shareholders | Foreign-owned, managed from abroad | Settlor transfers to trustee; beneficiaries hold equitable interests | Founder endows assets; council administers for beneficiaries | ≥1 GP (unlimited liability) + ≥1 LP (capped contribution) | Core company with cell investors | 100% local or foreign |
Minimum directors | At least 2 resident directors | Not required (managed externally) | N/A — governed by trustee | ≥1 Mauritius-resident council member | N/A — governed by GP | Directors of core company | 1 |
Minimum capital | No statutory minimum | No statutory minimum | No minimum (settlor settles assets) | No statutory minimum (founder endows assets) | No statutory minimum | No universal minimum capital for a PCC; capital depends on the regulated activity | No minimum |
Audit | Mandatory — audited accounts in Mauritius | Financial Summary filed with FSC | Not required (trustee accounting obligations) | Not required (council accounting obligations) | Annual return and accounts | Financial reporting and audit requirements apply in accordance with the PCC's underlying regulated activity and applicable legislation. | Audited unless qualified as a small private company (annual turnover does not exceed Rs 100 million) |
FSC licensing | Global Business Licence (GBL) required | Registered agent (MC) required; no GBL | Qualified trustee required (Mauritius-licensed) | Registered agent (FSC-licensed MC) required | FSC application if conducting global business | PCC core licensed by FSC; cells carrying regulated activities are subject to the applicable FSC approval/licensing requirements | Not required |
Typical uses | Holding, IP, treasury, regional HQ, fund umbrella | Offshore holding, financing, trading, real-estate SPV | Succession, wealth structuring, asset protection, family office | Civil-law wealth structures, succession, philanthropy, family-business holding | PE, VC, private credit, real-estate partnerships, joint ventures | Captive insurance, reinsurance, multi-strategy CIS, structured finance | Local operations, property holding, subsidiaries |
Substance requirements | CIGA in/from Mauritius, resident directors, local board meetings, principal bank account | Central management and control outside Mauritius | Licensed trustee; trust deed; beneficial-ownership records | Council with resident member; registered agent; beneficial-ownership records | GP with full liability; limited partnership agreement | PCC core licensed; cell approvals as applicable to regulated activities; statutory ring-fencing observed | Minimal — registered office and company secretary |
Privacy & reporting | Annual FSC and MRA returns; beneficial-ownership register | Financial Summary to FSC; beneficial-ownership at registered office | Not registered publicly; FATCA/CRS classification applies | Registered with Registrar; FATCA/CRS classification applies | Annual return; beneficial-ownership records | FSC and prudential reporting; audit requirements per applicable regime | Annual return and beneficial-ownership register |
Setup time | 4–6 weeks | 2–3 weeks | 2–4 weeks | 4–6 weeks | 3–4 weeks | Indicative establishment timeline: approximately 2–3 months, subject to regulatory approval, completeness of documentation and the circumstances of the application. | 1–2 weeks |
Ongoing complexity | Moderate — ongoing substance, audit and reporting obligations | Central management and control must be outside Mauritius | Low to moderate — trustee duties, deed maintenance, FATCA/CRS | Low to moderate — council governance, charter maintenance, FATCA/CRS | Low to moderate — GP obligations, annual return, potential FSC application | High — per-cell licensing where applicable, audit and prudential reporting | Low |
Global Business Licence
Legal personality
Yes (separate legal entity)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — 45+ double-taxation agreements
Ownership
Majority non-resident shareholders
Minimum directors
At least 2 resident directors
Minimum capital
No statutory minimum
Audit
Mandatory — audited accounts in Mauritius
FSC licensing
Global Business Licence (GBL) required
Typical uses
Holding, IP, treasury, regional HQ, fund umbrella
Substance requirements
CIGA in/from Mauritius, resident directors, local board meetings, principal bank account
Privacy & reporting
Annual FSC and MRA returns; beneficial-ownership register
Setup time
4–6 weeks
Ongoing complexity
Moderate — ongoing substance, audit and reporting obligations
Authorised Company
Legal personality
Yes (separate legal entity)
Tax residence
Non-resident (central management outside Mauritius)
Treaty eligibility
No
Ownership
Foreign-owned, managed from abroad
Minimum directors
Not required (managed externally)
Minimum capital
No statutory minimum
Audit
Financial Summary filed with FSC
FSC licensing
Registered agent (MC) required; no GBL
Typical uses
Offshore holding, financing, trading, real-estate SPV
Substance requirements
Central management and control outside Mauritius
Privacy & reporting
Financial Summary to FSC; beneficial-ownership at registered office
Setup time
2–3 weeks
Ongoing complexity
Central management and control must be outside Mauritius
Trust
Legal personality
No (trustee holds legal title)
Tax residence
Tax treatment depends on residence, source and nature of income. A non-resident trust is generally taxable in Mauritius on chargeable income attributable to Mauritius-source income. Partial exemptions may be available on qualifying income subject to statutory conditions
Treaty eligibility
No (trust itself is not a taxable entity)
Ownership
Settlor transfers to trustee; beneficiaries hold equitable interests
Minimum directors
N/A — governed by trustee
Minimum capital
No minimum (settlor settles assets)
Audit
Not required (trustee accounting obligations)
FSC licensing
Qualified trustee required (Mauritius-licensed)
Typical uses
Succession, wealth structuring, asset protection, family office
Substance requirements
Licensed trustee; trust deed; beneficial-ownership records
Privacy & reporting
Not registered publicly; FATCA/CRS classification applies
Setup time
2–4 weeks
Ongoing complexity
Low to moderate — trustee duties, deed maintenance, FATCA/CRS
Foundation
Legal personality
Yes (separate legal entity)
Tax residence
Tax treatment depends on residence, source and nature of income. A non-resident foundation is generally taxable in Mauritius on chargeable income attributable to Mauritius-source income. Partial exemptions may be available on qualifying income subject to statutory conditions
Treaty eligibility
No (foundation itself is not treaty-eligible)
Ownership
Founder endows assets; council administers for beneficiaries
Minimum directors
≥1 Mauritius-resident council member
Minimum capital
No statutory minimum (founder endows assets)
Audit
Not required (council accounting obligations)
FSC licensing
Registered agent (FSC-licensed MC) required
Typical uses
Civil-law wealth structures, succession, philanthropy, family-business holding
Substance requirements
Council with resident member; registered agent; beneficial-ownership records
Privacy & reporting
Registered with Registrar; FATCA/CRS classification applies
Setup time
4–6 weeks
Ongoing complexity
Low to moderate — council governance, charter maintenance, FATCA/CRS
Limited Partnership
Legal personality
Optional (electable at registration)
Tax residence
Generally fiscally transparent for Mauritius income-tax purposes; a resident société holding a GBL may elect to be taxed at company level, subject to the applicable tax rules
Treaty eligibility
Depends on entity-level tax residence
Ownership
≥1 GP (unlimited liability) + ≥1 LP (capped contribution)
Minimum directors
N/A — governed by GP
Minimum capital
No statutory minimum
Audit
Annual return and accounts
FSC licensing
FSC application if conducting global business
Typical uses
PE, VC, private credit, real-estate partnerships, joint ventures
Substance requirements
GP with full liability; limited partnership agreement
Privacy & reporting
Annual return; beneficial-ownership records
Setup time
3–4 weeks
Ongoing complexity
Low to moderate — GP obligations, annual return, potential FSC application
Protected Cell Company
Legal personality
One entity with statutorily segregated cells
Tax residence
GBL regime applies (typically)
Treaty eligibility
Yes, if structured as GBL
Ownership
Core company with cell investors
Minimum directors
Directors of core company
Minimum capital
No universal minimum capital for a PCC; capital depends on the regulated activity
Audit
Financial reporting and audit requirements apply in accordance with the PCC's underlying regulated activity and applicable legislation.
FSC licensing
PCC core licensed by FSC; cells carrying regulated activities are subject to the applicable FSC approval/licensing requirements
Typical uses
Captive insurance, reinsurance, multi-strategy CIS, structured finance
Substance requirements
PCC core licensed; cell approvals as applicable to regulated activities; statutory ring-fencing observed
Privacy & reporting
FSC and prudential reporting; audit requirements per applicable regime
Setup time
Indicative establishment timeline: approximately 2–3 months, subject to regulatory approval, completeness of documentation and the circumstances of the application.
Ongoing complexity
High — per-cell licensing where applicable, audit and prudential reporting
Domestic Company
Legal personality
Yes
Tax residence
Yes (Mauritius)
Treaty eligibility
Yes, potentially
Ownership
100% local or foreign
Minimum directors
1
Minimum capital
No minimum
Audit
Audited unless qualified as a small private company (annual turnover does not exceed Rs 100 million)
FSC licensing
Not required
Typical uses
Local operations, property holding, subsidiaries
Substance requirements
Minimal — registered office and company secretary
Privacy & reporting
Annual return and beneficial-ownership register
Setup time
1–2 weeks
Ongoing complexity
Low
General guidance only. This comparison is general information only and does not constitute legal or tax advice. Specific requirements depend on your jurisdiction, activity and circumstances. Consult our team for tailored guidance.
Compare — Financial Services & Licensing
Select two structures to compare:
| VCC | CIS | ID | IA | CIS Mgr | VASP | PI | 08 | 09 | |
|---|---|---|---|---|---|---|---|---|---|
Legal personality | VCC and (optionally) each sub-fund | Yes (fund vehicle) | Yes (GBL) | Yes (GBL) | Yes (GBL) | Yes (GBL) | Yes (GBL or AC) | Yes (GBL) | Yes (GBL) |
Tax residence | Tax-resident in Mauritius | Depends on sub-type; SPF: specific exemptions/treatment apply subject to the Income Tax Act and conditions | Tax-resident in Mauritius | Tax-resident in Mauritius | Tax-resident in Mauritius | Tax-resident in Mauritius | Tax-resident in Mauritius (GBL) | Tax-resident in Mauritius | Tax-resident in Mauritius |
Treaty eligibility | Yes — via GBL at umbrella level | Depends on fund structure and tax residence | Yes — extensive treaty network | Yes — extensive treaty network | Yes — extensive treaty network | Yes — extensive treaty network | Yes — extensive treaty network (GBL) | Yes — extensive treaty network | Yes — extensive treaty network |
Ownership | Umbrella company; sub-fund investors | Investors hold fund units/shares | 100% local or foreign | 100% local or foreign | 100% local or foreign | 100% local or foreign | 100% local or foreign | 100% local or foreign | 100% local or foreign |
Minimum directors | Directors of VCC company | Board of fund vehicle | 2 resident directors | 2 resident directors | 2 resident directors | 2 resident directors | 2 resident directors | 2 resident directors | 2 resident directors |
Minimum capital | Per GBL requirements | Varies by sub-type (Expert Investor generally invests at least USD 100,000, but sophisticated investors also qualify) | MUR 600K–10M depending on category | Unrestricted: MUR 600,000 · Restricted: MUR 500,000 · Corporate Finance Advisory: MUR 1,000,000 | MUR 1 million | Varies by VASP category | MUR 2,000,000 minimum stated unimpaired capital (or currency equivalent) | As prescribed by FSC | Varies by licence category |
Audit | Audited financial statements per sub-fund | Audited financial statements to be filed in Mauritius | Annual audit required | Annual audit required | Annual audit required | Annual audit required | Annual audit required | Annual audit required | Annual audit required |
FSC licensing | VCC is authorised as a VCC Fund; individual sub-funds/SPVs are separately identified/authorised within the VCC regulatory framework | CIS Manager and CIS Administrator appointed | Investment Dealer Licence required | Investment Adviser Licence required | CIS Manager Licence required | VASP Licence (VAITOS Act 2021) required | Payment Institution Licence required | Insurance Brokerage Licence required | Relevant FSC licence required |
Typical uses | Multi-strategy funds, Africa-focused managers, master/feeder, family-office platforms | Hedge funds, retail mutual funds, real-estate/infrastructure, family pooled vehicles | Stockbroking, portfolio management, underwriting | Advisory, portfolio management, corporate finance | Fund administration, NAV, transfer agency, distribution | Exchanges, custody, wallet services, advisory, marketplace | Payment intermediary services, acquiring, remittance | Insurance brokerage, reinsurance intermediation, risk advisory | Forex, insurance, pension, family office, custody |
Substance requirements | Ring-fencing observed; FSC reporting at umbrella and sub-fund level | CIS Manager and Administrator in Mauritius | CIGA, resident directors, IDT team | CIGA, resident directors, compliance officer | CIGA, resident directors, investment committee | CIGA, resident directors, AML/CFT, travel rule | CIGA, resident directors, AML/CFT | CIGA, resident directors, compliance officer | Substance, governance, capital, staffing and local-presence requirements vary according to the applicable licence and activity. |
Privacy & reporting | FSC reporting; FATCA/CRS at investor level per sub-fund | Annual FSC reporting; ongoing disclosures; audited statements filed | Annual FSC reporting, audited financials | Annual FSC reporting, audited financials | Annual FSC reporting, audited financials | Annual FSC reporting, transaction monitoring | Annual FSC reporting | Annual FSC reporting, audited financials | Annual FSC reporting, audited financials |
Setup time | Indicative establishment timeline: approximately 2–3 months, subject to regulatory approval, completeness of documentation and the circumstances of the application. Indicative timeline only. Actual processing time depends on completeness of documentation, complexity of the application, regulatory queries and approval by the FSC or other competent authority. | 2–3 months. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. Indicative timeline only. Actual processing time depends on completeness of documentation, complexity of the application, regulatory queries and approval by the FSC or other competent authority. | 8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. | 8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. | 8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. | 16–28 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. | 8–12 weeks | 8–12 weeks | Varies by licence category |
Ongoing complexity | Moderate — shared infrastructure but per-sub-fund licensing and reporting | High for Retail (full regulation); lighter for Expert/SPF | High — IDT, compliance, PII, FSC reporting | Moderate — compliance, FSC reporting | Moderate — compliance, FSC reporting, NAV | High — AML, travel rule, sanctions, FSC reporting | Moderate — compliance, FSC reporting | Moderate — compliance, PII, FSC reporting | Varies by licence category |
Variable Capital Company
Legal personality
VCC and (optionally) each sub-fund
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — via GBL at umbrella level
Ownership
Umbrella company; sub-fund investors
Minimum directors
Directors of VCC company
Minimum capital
Per GBL requirements
Audit
Audited financial statements per sub-fund
FSC licensing
VCC is authorised as a VCC Fund; individual sub-funds/SPVs are separately identified/authorised within the VCC regulatory framework
Typical uses
Multi-strategy funds, Africa-focused managers, master/feeder, family-office platforms
Substance requirements
Ring-fencing observed; FSC reporting at umbrella and sub-fund level
Privacy & reporting
FSC reporting; FATCA/CRS at investor level per sub-fund
Setup time
Indicative establishment timeline: approximately 2–3 months, subject to regulatory approval, completeness of documentation and the circumstances of the application. Indicative timeline only. Actual processing time depends on completeness of documentation, complexity of the application, regulatory queries and approval by the FSC or other competent authority.
Ongoing complexity
Moderate — shared infrastructure but per-sub-fund licensing and reporting
CIS / Closed-End Funds
Legal personality
Yes (fund vehicle)
Tax residence
Depends on sub-type; SPF: specific exemptions/treatment apply subject to the Income Tax Act and conditions
Treaty eligibility
Depends on fund structure and tax residence
Ownership
Investors hold fund units/shares
Minimum directors
Board of fund vehicle
Minimum capital
Varies by sub-type (Expert Investor generally invests at least USD 100,000, but sophisticated investors also qualify)
Audit
Audited financial statements to be filed in Mauritius
FSC licensing
CIS Manager and CIS Administrator appointed
Typical uses
Hedge funds, retail mutual funds, real-estate/infrastructure, family pooled vehicles
Substance requirements
CIS Manager and Administrator in Mauritius
Privacy & reporting
Annual FSC reporting; ongoing disclosures; audited statements filed
Setup time
2–3 months. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval. Indicative timeline only. Actual processing time depends on completeness of documentation, complexity of the application, regulatory queries and approval by the FSC or other competent authority.
Ongoing complexity
High for Retail (full regulation); lighter for Expert/SPF
Investment Dealer
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
MUR 600K–10M depending on category
Audit
Annual audit required
FSC licensing
Investment Dealer Licence required
Typical uses
Stockbroking, portfolio management, underwriting
Substance requirements
CIGA, resident directors, IDT team
Privacy & reporting
Annual FSC reporting, audited financials
Setup time
8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval.
Ongoing complexity
High — IDT, compliance, PII, FSC reporting
Investment Adviser
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
Unrestricted: MUR 600,000 · Restricted: MUR 500,000 · Corporate Finance Advisory: MUR 1,000,000
Audit
Annual audit required
FSC licensing
Investment Adviser Licence required
Typical uses
Advisory, portfolio management, corporate finance
Substance requirements
CIGA, resident directors, compliance officer
Privacy & reporting
Annual FSC reporting, audited financials
Setup time
8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval.
Ongoing complexity
Moderate — compliance, FSC reporting
CIS Manager
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
MUR 1 million
Audit
Annual audit required
FSC licensing
CIS Manager Licence required
Typical uses
Fund administration, NAV, transfer agency, distribution
Substance requirements
CIGA, resident directors, investment committee
Privacy & reporting
Annual FSC reporting, audited financials
Setup time
8–12 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval.
Ongoing complexity
Moderate — compliance, FSC reporting, NAV
Virtual Asset Service Providers
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
Varies by VASP category
Audit
Annual audit required
FSC licensing
VASP Licence (VAITOS Act 2021) required
Typical uses
Exchanges, custody, wallet services, advisory, marketplace
Substance requirements
CIGA, resident directors, AML/CFT, travel rule
Privacy & reporting
Annual FSC reporting, transaction monitoring
Setup time
16–28 weeks. All timelines are indicative and subject to completeness, FSC review, regulatory queries and approval.
Ongoing complexity
High — AML, travel rule, sanctions, FSC reporting
Payment / Financial Institutions
Legal personality
Yes (GBL or AC)
Tax residence
Tax-resident in Mauritius (GBL)
Treaty eligibility
Yes — extensive treaty network (GBL)
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
MUR 2,000,000 minimum stated unimpaired capital (or currency equivalent)
Audit
Annual audit required
FSC licensing
Payment Institution Licence required
Typical uses
Payment intermediary services, acquiring, remittance
Substance requirements
CIGA, resident directors, AML/CFT
Privacy & reporting
Annual FSC reporting
Setup time
8–12 weeks
Ongoing complexity
Moderate — compliance, FSC reporting
Insurance Brokerage
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
As prescribed by FSC
Audit
Annual audit required
FSC licensing
Insurance Brokerage Licence required
Typical uses
Insurance brokerage, reinsurance intermediation, risk advisory
Substance requirements
CIGA, resident directors, compliance officer
Privacy & reporting
Annual FSC reporting, audited financials
Setup time
8–12 weeks
Ongoing complexity
Moderate — compliance, PII, FSC reporting
Other FSC Regulated Structures & Licences
Legal personality
Yes (GBL)
Tax residence
Tax-resident in Mauritius
Treaty eligibility
Yes — extensive treaty network
Ownership
100% local or foreign
Minimum directors
2 resident directors
Minimum capital
Varies by licence category
Audit
Annual audit required
FSC licensing
Relevant FSC licence required
Typical uses
Forex, insurance, pension, family office, custody
Substance requirements
Substance, governance, capital, staffing and local-presence requirements vary according to the applicable licence and activity.
Privacy & reporting
Annual FSC reporting, audited financials
Setup time
Varies by licence category
Ongoing complexity
Varies by licence category
General guidance only. This comparison is general information only and does not constitute legal or tax advice. Specific requirements depend on your jurisdiction, activity and circumstances. Consult our team for tailored guidance.
Get started
Start with a conversation.
Tell us what you're building and where you're based. We'll show you if Mauritius is the right solution, and if it is, design the structure that fits.