Mauritius

Mauritius is widely used as a mid-shore gateway because of its deep double-tax-treaty and bilateral-investment-treaty network, a bilingual common-law judiciary with final appeal to the Judicial Committee of the Privy Council, and a credible regulatory reputation reinforced by its 2021 removal from the FATF gray list and the EU AML list. These features make it a frequent domicile for institutional capital, development-finance institutions and fund managers deploying into African and Indian markets, though treaty access increasingly depends on demonstrable substance.

Treaty access is the difference. A Global Business Corporation (GBC) holds a Global Business Licence from the FSC, is tax-resident in Mauritius and can seek treaty benefits, so it must show core income-generating activities, resident directors and local expenditure. An Authorised Company is managed and controlled outside Mauritius, generally not treaty-eligible and lighter to run. Both sit under the Companies Act 2001. A GBC means paying for substance every year, worthwhile when treaty access or Mauritian residence is the objective.

No. Hart David Carson does not maintain an office in Mauritius and does not act as a registered agent, management company or bank. Incorporation, licensing and account opening are carried out by FSC-licensed management companies, fiduciaries and banks, with all local advice and filings delivered by locally admitted counsel. Our role is to scope the structure and coordinate these facilitators as a partner network, without guaranteeing any particular regulatory, banking or tax outcome.

A GBC pays a 15% headline rate, can use a partial exemption that brings the effective rate down on qualifying foreign-source income, and must prove substance every year. To rely on treaty benefits, it must conduct its core income-generating activities in Mauritius, keep an adequate number of qualified resident directors, and carry proportionate local expenditure and premises. Mauritius applies CRS and FATCA reporting, and substance and the principal-purpose test increasingly gate treaty access under the relevant instruments.

Trusts under the Trusts Act 2001 and foundations under the Foundations Act 2012. The trust statute permits discretionary, purpose and charitable trusts with strong confidentiality protections; the foundation is a civil-law-style vehicle suited to succession and philanthropy. African and Indian families use both for estate planning, asset consolidation and intergenerational governance. The FSC-licensed fiduciary or management company that administers the vehicle completes due diligence on settlors and beneficiaries first, which sets the timetable; we coordinate it with locally admitted counsel.

Yes. Mauritius is an established domicile for Africa-focused private equity and development-finance co-investment vehicles, formed as Collective Investment Schemes or Closed-End Funds under the Securities Act 2005 and FSC rules, with the Variable Capital Company (VCC) introduced in 2022 for umbrella and multi-strategy platforms. For a manager the practical point is diligence: substance, beneficial ownership and source of wealth are examined before launch, so have that file ready early. We coordinate licensing pathways through FSC-licensed providers and locally admitted counsel.