GBL vs Authorised Company: Choosing the Right Mauritius Structure

When establishing a corporate presence in Mauritius, the choice typically comes down to two vehicles: the Global Business Corporation (GBL) and the Authorised Company (AC). Both are governed by the Financial Services Act 2007 and supervised by the FSC, but they serve fundamentally different purposes. The right choice depends on whether you need treaty access and are willing to meet the substance that comes with it.

Tax Residence and Treaty Access

The GBL is tax-resident in Mauritius. It is incorporated under Part X of the Financial Services Act and is subject to Mauritian corporate income tax at the headline rate of 15%. Qualifying foreign-source income may benefit from an 80% Partial Exemption Regime, subject to applicable statutory and substance requirements, resulting in an effective rate of approximately 3%. Critically, a GBL can access Mauritius's network of 45+ double-taxation agreements, making it the vehicle of choice for cross-border investment holding, treasury and IP structures.

The AC is non-resident for Mauritius tax purposes. It is incorporated under Part XI of the Financial Services Act and is not subject to Mauritian income tax. The trade-off is that an AC cannot access Mauritius's tax treaties. It is suitable for activities where treaty relief is not required, typically trading, consulting or service operations that do not involve dividend or interest flows from treaty jurisdictions.

Substance Requirements

A GBL must maintain two resident directors, principal banking in Mauritius, audited accounts prepared locally, board meetings chaired in Mauritius, and core income-generating activities aligned with the income source. The Finance Act 2025 reinforced that substance must be satisfied by the activity that generates the income, not merely by the entity.

The AC has lighter obligations. It requires a registered office and agent in Mauritius but does not need resident directors or local board meetings. The AC is designed for entities that are managed and controlled outside Mauritius.

Cost and Speed

An AC is faster and cheaper to establish. From a complete KYC file, incorporation takes approximately two to three weeks. A GBL typically takes four to six weeks, running incorporation and bank account opening in parallel. Annual compliance costs are higher for a GBL due to the audit, resident director and substance requirements.

When to Use Which

The decision is not permanent: an AC can be converted to a GBL (and vice versa) as circumstances change. The key is to match the vehicle to the objective at the outset, so the structure works from day one rather than requiring reorganisation later.