Global Business Licence (GBL)
A Global Business Licence (GBL) is a tax resident company which benefits from the network of DTAAs which Mauritius has with various countries. A GBL can be structured as a Collective Investment Scheme (“CIS”), Closed-End Fund, Fund Manager, Investment Adviser, Protected Cell Company or investment holding entity. In addition, a Trust, Foundation or Limited Partnership may seek a GBL licence.A Global Business Licence is issued in Mauritius where the majority of shares or voting rights are held by a person who is not a citizen of Mauritius and the GBL conducts business outside Mauritius.
A GBL benefits from a Partial Exemption Regime (income tax exemption of 80%),applied to certain types of income provided that substance requirement criteria are met.
It is also important for the GBL to demonstrate management and control in Mauritius in order to satisfy substance requirements, which are as follows:
- Be managed and controlled from Mauritius.
- Be administered by a Management Company.
- Carry out its core income generating activities in, or from, Mauritius, as required under the Income Tax Act –
(A) employing, either directly or indirectly, a reasonable number of suitably qualified persons to carry out the
core activities; and
(B) having a minimum level of expenditure, which is proportionate to its level of activities;