Structures / GBL
Global Business Licence
The treaty-eligible Mauritius company.
A Mauritius-incorporated company holding a Global Business Licence issued by the FSC, commonly used for international investment, holding, financing and cross-border business activities. A GBL is tax resident in Mauritius subject to applicable tax residence requirements.
At a glance
- Statute
- FSA 2007, Part X
- Tax
- 15% headline rate; effective rates can be as low as 3% on qualifying income, subject to applicable conditions
- Treaty access
- Yes (45+ double-taxation agreements)
- Resident directors
- At least 2
- Min capital
- No statutory minimum
- Substance
- CIGA in / from Mauritius
- Principal bank account
- Mauritius
Used for
- 01
International investment holding — cross-border equity and portfolio investment via the 45+ double-taxation agreements. The GBL itself is the holding company; no separate licence required for passive investment holding.
- 02
IP and royalty holding — requires careful transfer-pricing compliance and may need separate IP licensing depending on jurisdiction. The GBL holds the IP assets; any licensing or commercialisation activity may require additional regulatory approvals in the relevant jurisdiction.
- 03
Treasury and intra-group financing — subject to transfer-pricing rules, thin-capitalisation limits and potential withholding-tax implications in borrower jurisdictions. The GBL acts as the financing entity; lending to third parties may require separate banking or financial-services licensing.
- 04
Regional headquarters into Africa or Asia — substance requirements must be met through CIGA, resident directors and local board meetings. The GBL is the holding and management entity; operating subsidiaries in target markets may need their own local licences.
- 05
Fund structures — A GBL may be used for a Mauritius fund structure, subject to the applicable FSC authorisation. Depending on the structure, the fund may appoint a licensed CIS Manager or may be structured as a self-managed scheme, subject to FSC approval and the applicable regulatory requirements. Other functions, including fund administration, NAV calculation, transfer agency and investor reporting, may be performed by appropriately appointed service providers in accordance with the applicable regulatory framework.
- 06
Insurance and captive holding — a PCC or separate insurance licence from the FSC is required for insurance-related activities. The GBL can own the captive or insurance vehicle; the insurance activity itself must be separately licensed under the Insurance Act 2007.
Ongoing obligations
- 01
Two resident directors with appropriate calibre
- 02
Principal banking in Mauritius
- 03
Audited accounts prepared in Mauritius
- 04
Board meetings chaired from Mauritius
- 05
Resident company secretary and registered office
- 06
Annual FSC and MRA reporting
Designed For
International holding groups
Cross-border investment into Africa and Asia via the 45+ double-taxation agreements.
IP and treasury platforms
Centralised IP holding, royalty, and intra-group treasury.
Fund umbrella vehicles
Licensed GBL platform for multi-strategy fund structures.
Regional operating HQs
Headquarters for African or Asian subsidiaries.
How AcuFin supports it
Common questions
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