Matching the company to the purpose
Mauritius may serve as an operating base, regional holding, investment or service jurisdiction for Africa- and Asia-related projects. The starting point is not the tax rate but where decisions, staff, counterparties and banking relationships are located.
A domestic company is suited to activity in Mauritius. A Global Business Licence applies to resident corporations conducting business mainly outside Mauritius and is obtained through a licensed management company under FSC supervision. An Authorised Company follows a different management model and should not be presented as a Mauritius tax resident.
- the structure’s purpose and source countries of income;
- the place of central management and control;
- the need for tax residence and treaty access;
- licensing implications and the local administrator’s role;
- banking, accounting, audit and beneficial ownership disclosure.
The tax regime: what requires verification
The Mauritius Revenue Authority states a standard 15% corporate tax rate and a 3% rate for specified export and other qualifying activities. Certain income may qualify for a partial exemption if statutory conditions are met. These rules cannot be applied by income label alone: source, functions, expenditure, activity classification and economic substance all matter.
A Fair Share Contribution applies from 1 July 2025 to certain companies above the relevant chargeable-income threshold. Effective tax analysis should therefore include not only corporate income tax but also temporary contributions, VAT, withholding, foreign tax credits and the rules of the owners’ home countries.
The Russia treaty and treaty access
The earlier suggestion that the Mauritius–Russia double tax treaty could already be relied upon should not be retained. At the review date, the MRA lists the Russia treaty among agreements awaiting ratification and the notifications required for entry into force.
Even after entry into force, a treaty rate is not automatic. Tax residence, beneficial ownership, commercial purpose, the principal purpose test, actual functions and the domestic rules of both countries generally require analysis. The treaty’s status and the particular structure’s eligibility should be confirmed before a transaction.
Trademarks and intellectual property
Company incorporation does not protect a brand automatically. Before filing, the owner, goods and services, mark availability and countries of actual use should be reviewed. An international group must separately decide which entity owns the mark and on what terms operating companies may use it.
Before transferring a mark or charging royalties, transfer pricing, withholding tax, the IP owner’s substance and the commercial rationale for payments require review. Trademark registration alone does not validate a licensing or tax model.
How SGC coordinates the project
We map owners, cash flows, agreements and connected countries, compare Mauritius with alternatives and prepare one brief for a licensed management company, tax advisers and IP specialists.
The result is not merely incorporation but an aligned package: corporate governance, a banking plan, documented tax assumptions, a compliance calendar, intra-group agreements and annual review points.