Treaty network and substance
Holding Company & Investment Structures in Mauritius
Mauritius is a long-established holding jurisdiction for Africa and Asia. Its value depends entirely on substance.
GCC business setup specialists
The treaty network is the point
Mauritius built its position on an extensive treaty network, particularly into Africa and India. Those treaties are now applied with far more scrutiny, and a holding company without genuine substance is unlikely to obtain the benefits it was created for.
- Structure matched to the investment destination
- Substance requirements set out before you commit
- Honest about where treaty claims will be tested
20+
Mainland, free zone and offshore jurisdictions we file in — so the recommendation is based on your activity, not on which authority we happen to be registered with.
7,000+
Companies successfully established.
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The options
Ways to hold from Mauritius
The regime decides whether treaties are available at all.
| Structure | What it is for | Treaty access |
|---|---|---|
| Global Business Company | Holding investments into treaty partners | Possible with genuine substance |
| Authorised Company | Holding without treaty reliance | No — treated as non-resident |
| Domestic company | Holding Mauritian assets | Resident, but local focus |
| Limited partnership | Fund and joint venture structures | Depends on the structure |
| Protected cell company | Segregated portfolios | Per the licence |
| Foundation | Succession and philanthropy | A different legal concept |
Treaty access depends on substance and is tested both in Mauritius and in the counterparty country. Positions change and are subject to international scrutiny. A Global Business Company must be administered by a management company licensed by the Financial Services Commission, and an Authorised Company must have a licensed registered agent. That is a statutory requirement in Mauritius. We co-ordinate your engagement with a licensed Mauritian management company and manage the process end to end; the regulated filings are made by them.
How it works
Setting the structure up
Where you are investing decides whether Mauritius helps.
01
Destination and purpose
Where the investments will be, and whether a treaty between Mauritius and that country is genuinely relevant to you.
02
Regime and substance
Global Business Company with substance, or Authorised Company without. We set out what substance would cost and involve.
03
Incorporate and hold
Company incorporated, resident directors appointed, local bank account opened and the holdings transferred in.
Before you start
What we need
Structuring rests on the destination and the substance you will actually have.
- What the structure will hold
- Where the investments are located
- Whether treaty benefits are being relied on
- Existing group structure chart
- Certified identity documents for controllers
- Source of funds and wealth evidence
- Who will be the resident directors
- Where board meetings will be held
- Expected income and dividend flows
- Existing shareholder agreements
- Advice already received in the destination country
- Timeline and what is driving it
Scope
What is included, and what is not
Stated plainly, so nothing is added once the engagement starts.
Included in the service fee
- Regime recommendation against the destination
- Substance requirements set out in writing
- Management company engagement co-ordinated
- Incorporation and licence application
- Resident director arrangements
- Share registers and statutory records
- Local bank account introduction
- Tax registration and filing calendar
Not included, quoted separately
- Registrar, FSC and MRA fees, paid at cost
- Management company annual fees
- Tax advice in the destination country
- Formal opinions on treaty positions
- Tax residence certificate applications, quoted separately
- Substance costs such as office and staff
- Annual audit
- Valuations
Verify independently
Official Mauritian authorities
We file directly with these bodies on your behalf.
Corporate and Business Registration DepartmentFinancial Services CommissionMauritius Revenue AuthorityEconomic Development BoardRegistrar of CompaniesIndustrial Property Office
Questions
Mauritius holding structures — FAQs
Why hold through Mauritius?
An extensive treaty network, particularly into Africa and India, no capital gains tax and an established professional sector. Its value depends on substance.
Are Mauritius treaty claims still accepted?
They are scrutinised far more than they once were, both in Mauritius and in the counterparty country. A structure without real substance is unlikely to succeed, and we will say so.
What substance is required?
Resident directors, board meetings held in Mauritius, a local principal bank account and core income-generating activity here, with appropriate expenditure and employment.
Is an Authorised Company useful for holding?
Yes, where treaty access is not needed. It is cheaper and simpler precisely because it is treated as non-resident.
Do I need advice in the destination country?
Almost always, and we will say when. Mauritius advice alone does not settle how a claim will be treated at the other end.
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