Background:
About 1500 miles from the coast of Southern Africa in the Indian Ocean, lies Mauritius. Its population is approximately 1,100,000 of which most people are of European, African, Indian, Madagascan and Chinese origin. The official language is English although they are bilingual in both English and French. Creole is also understood by everyone.

Apart from the double tax treaty with India, Mauritius also has treaties with UK, France, Germany, Malaysia, South Africa, Sweden and Zimbabwe.

Type of Company(s):
There are two types of companies which the Mauritian Companies Act recognizes.

  • The Offshore Company registered under the Companies Act 1984
  • The International Company (IC's) registered under the Companies Act 1984

The Offshore Company is the only one that can be used for Mauritian double tax treaties.

Taxation:
The Offshore Mauritius Company can operate within Mauritius without having to pay any tax and there is no capital, income, estate or inheritance taxation and no withholding tax on dividend interests and royalties. If so desired an Offshore Company can voluntarily opt to pay income tax at a minimum rate of 35% of its chargeable income. Care must be taken to ensure that full use can be made of the double tax treaties. Before obtaining the resident tax certificate which qualifies the company for double tax treaties, the following points are to be considered:
  • Minimum of two Mauritius directors
  • A Mauritius resident secretary
  • Registered Office in Mauritius
  • Board meetings held in Mauritius
  • Accounts prepared in Mauritius and audited by Mauritius auditors
    •
  • A bank account with an offshore bank in Mauritius having funds operating through the account.

There is the possibility for the use of  nominee shareholders to safeguard the anonymity of the beneficial owner, although the Mauritius Offshore Business Activities Authority (MOBAA) requires the identity of the ultimate beneficial owners. The legislation governing the offshore business activities protects the secrecy of the parties involved.

An offshore company must hold an Annual General Meeting and file an Annual Return together with audited accounts.

There is an annual licence fee of $1,500 and offshore companies are exempt from Mauritian exchange control.