A GBC1 is taxed on its chargeable income (including dividends, interests and other income but not capital gains less expenses) at a corporate rate of 15% which is reduced to a net effective tax rate of 3% or even less:
Net Rate %
Normal tax rate
15%
Less
EITHER
Deemed tax credit of 80% on foreign sourced income – 80% of 15%
(12%)
3
OR
Actual foreign tax credit, if written evidence is available where then the tax payment in Mauritius can even be
(Actual foreign tax credit)
Nil
Foreign Tax Credit
If there is written evidence of foreign tax paid, the GBC1 can claim the higher of the deemed tax credit of 80% or the foreign tax credit against Mauritian tax for actual:
withholding taxes suffered abroad on income remitted to Mauritius;
foreign corporation tax charged on income out of which dividend is paid (i.e the underlying tax credit) if the GBC1 holds not less than 5% of the share capital of the company paying the dividend.
In the absence of evidence, the amount of foreign tax shall nevertheless be conclusively presumed to be 80% of the Mauritian tax chargeable with respect to that income.
Other Taxes
A GBC1 is exempt from capital gains tax in Mauritius.
All payments by a GBC1 whether by way of dividends, interest or royalties are not subject to any Mauritian withholding tax or levy.
Non-resident shareholders are not subject to any tax or other liability as holder or beneficial owner of shares in a GBC1.
A GBC1 is exempted from payment of any Mauritian registration, capital, stamp or other duty or similar charges.
