Look beyond the label.

1. Three layers, three different questions

“GBC”, “trust” and “investment dealer” are not interchangeable descriptions. Start by separating the legal person, its regulatory permission and the income or transaction being taxed. Then add residence, source and the relevant period.

A company may hold a Global Business Licence and an investment dealer licence. The first licence does not replace the company; the second does not turn every receipt into qualifying investment-dealer income. Its client assets are not automatically its own income.

Layer	What to establish	Why it matters
Legal structure	Company, trust, foundation, société, partnership, unit trust or another statutory arrangement	Identifies the taxpayer, computation and treatment of distributions
Regulatory permission	Exact licence, approval, registration or authorisation and permitted activity	May be a condition for relief, but does not prove every other condition
Tax facts	Residence, source, income character, expenses, substance, thresholds and dates	Determines the tax treatment of the particular income or transaction

Keep these layers separate on a working paper. A marketing description such as “offshore company” is not a substitute for any of them.

2. The main vehicles

Domestic company

An ordinary company starts with the 15% rate on chargeable income under the Income Tax Act’s First Schedule. Chargeable income is a statutory computation, not turnover or the cash left in a bank account. Residence and source determine the income within the charge; deductions, losses and relief then need their own tests.

For a local consultancy, salaries, rent and other expenses require a deduction analysis. Its invoices require a separate VAT analysis. Paying employees introduces PAYE and contribution obligations. Purchasing property can introduce registration and land-related duties. 15% is not a complete list of the company’s obligations.

Global Business Licence holder

A Global Business Licence overlays the underlying legal structure. It does not establish a flat 3% tax on everything the business receives.

For an ordinary company otherwise taxed at 15%, an 80% exemption leaves 20% taxable. The arithmetic is 20% × 15% = 3% of the qualifying income, before considering expense attribution and other obligations. This result depends on the relevant statutory item, exclusions and substance conditions. It is not a universal company rate.

Qualifying foreign dividends, certain interest and specified licensed activities have different provisions. A single company may receive qualifying income, fully taxable income and income requiring a separate treatment. Keep separate schedules.

Example: Lotus Advisory Ltd holds a Global Business Licence. It earns advisory fees and receives a foreign dividend. Examine each income stream separately. The licence alone proves neither that the fees qualify under a specified activity exemption nor that the foreign dividend satisfies its conditions.

See the Income Tax Act, Second Schedule and regulation 23D, read with the Finance Act 2026.

Authorised Company

Section 73A addresses an Authorised Company whose central management and control are outside Mauritius. Non-resident status does not mean that Mauritius-source income can never be taxed, and it does not eliminate the return requirement in section 116.

Do not sell an AC as “automatically tax-free”. Document where management and control are exercised, identify any Mauritius-source income and check the source country’s rules. A non-resident AC must not be presumed eligible for treaty benefits reserved for Mauritius residents.

Trust

Section 46 contains specific trust rules. The trust’s own tax position and the beneficiary’s receipt are different questions. The current legislation treats a distribution to a beneficiary as a dividend for the relevant income-tax analysis.

Historic declaration-of-non-residence material must not be applied as though the former exemption remained universally available. Residence, settlor and beneficiary facts, the relevant tax year and current legislation all matter. The MRA’s Statement of Practice SP 24/21 provides interpretive context; later legislation takes priority.

Foundation

A foundation has its own rules under section 49A. Analyse its residence and taxable income before considering a distribution. The statute’s dividend treatment of distributions does not by itself answer the beneficiary’s final tax liability.

The ordinary exemption for dividends paid by a Mauritius-resident company remains in Second Schedule Part II, Sub-part B item 1. The 2026 deletion of Sub-part A item 1 concerns presidential emoluments, not dividends. For a trust or foundation distribution, read the statutory deemed-dividend treatment and the recipient’s position before applying the exemption or any other charge.

Sociétés, limited partnerships and LLPs

Section 47 generally allocates a resident société’s income to associates, including where that income has not been distributed, subject to relevant exceptions. Cash retained in the arrangement does not necessarily defer the associate’s tax.

Limited partnership and limited liability partnership analysis requires the precise statutory definition, residence and any applicable election. “Limited liability” describes legal exposure; it does not establish transparent taxation. This trial does not certify every partnership election or cross-border classification.

Funds, cells and specialised structures

Unit trust schemes have specific rules under section 45. REITs have a distinct conditional framework under section 49C. A Protected Cell Company or Variable Capital Company requires a map of the umbrella, cells, sub-funds, special-purpose vehicles and the statutory tax person.

Do not multiply the ordinary company calculation by the number of cells. Regulatory segregation of assets does not, by itself, establish a separate tax assessment. The trial flags compartment-level computations for specialist verification.

The structure directory summarises all twelve learning categories and their next checks.

3. Financial-services activities: start with the exact permission

The licence directory indexes the FSC’s published category list, the 2026 Private Wealth Management framework, and Bank of Mauritius activity families. It includes licences, approvals, registrations and recognitions because those permissions have different legal meanings. Every licence row now links to a facts sheet — nature, enabling law, holder, criteria, fees and neighbouring codes — and to its chapter in Special Licences. Tax relief stays in this course. A permission is not a tax holiday.

Activity family	First tax question	Frequent error
Investment dealers, advisers, CIS managers, administrators and asset managers	Does this person and its income satisfy the specified partial-exemption item and regulation 23D?	Extending a company’s relief to every representative or unrelated fee
CIS and closed-end funds	What is the tax person, and is the income interest or another category?	Using one effective rate for all fund receipts and investors
Leasing, factoring and credit finance	Do the interest-item exclusions apply? Is there a separate activity-specific provision?	Treating ordinary equipment finance like qualifying aircraft leasing
Banking	Apply the bank-specific framework, including section 44C and First Schedule Part III	Applying the ordinary company model to every bank
Non-bank deposit taking and cash dealing	Establish the institution’s classification and exclusions	Assuming all financial interest qualifies for 80% exemption
Insurance	Apply section 50 and regulation 17 to the relevant class of business	Taxing premiums as though they were ordinary service-company profit
Reinsurance and captives	Identify the exact relief item and its conditions	Extending reinsurance relief to an ordinary insurance broker
Pension arrangements	Separate the scheme, administrator, manager and beneficiary	Treating service-provider fees as exempt because the client is a pension scheme
Virtual assets, payments and crowdfunding	Classify each income stream and the permission actually held	Assuming a technology-related licence creates a tax holiday
Family offices and wealth management	Establish the current framework and exact incentive conditions	Treating a newly announced or enacted category as an operational tax exemption

For qualifying licensed or approved CIS and closed-end fund companies, the schedule distinguishes the 80% exemption for specified non-interest income from the 95% exemption for qualifying interest. For a simple, condition-satisfied income item, 95% exemption leaves 5% × 15% = 0.75% before other obligations. That arithmetic is neither an all-in fund tax rate nor a conclusion about investors.

The ordinary interest exemption expressly excludes specified financial businesses. Read those exclusions before doing any multiplication. Likewise, qualifying reinsurance and reinsurance-brokering income has its own 80% exemption item; ordinary insurance brokerage is not automatically included.

Bank calculations are a marked coverage gap in this trial. The directory identifies the bank-specific provisions and related levies but does not certify a numerical all-in bank model. The same restraint applies to specialised insurance, compartments and unresolved licence transitions.

4. Cross-cutting obligations

For each vehicle, run a second review beyond basic income tax:

• VAT: classify each supply, registration obligations, exemptions and input-tax recovery. Financial-sector status does not exempt every service.
• Withholding: identify the payment, recipient, source, domestic rule and any treaty. A royalty, dividend, salary and management fee need separate analysis.
• Employees: consider PAYE and applicable statutory contributions, even where the employer’s own income qualifies for relief.
• Other charges: test CSR, the corporate climate responsibility levy, company fair share contribution and qualified domestic minimum top-up tax against their own definitions, thresholds and exclusions.
• Transactions: review customs and excise for imports, and registration or land-related duties for relevant property transactions.
• Compliance: distinguish income-tax returns and advance payments from VAT, payroll and regulatory filings. Annual licence fees are not income tax.

The company fair share contribution is located in the VAT Act, but it is not simply VAT charged on a customer invoice. Finance Act 2026 section 25(o) amends its scope. An older summary that relies only on the former taxable-supplies condition can mislead.

A tax incentive may leave these other obligations intact. Conversely, an exclusion from one levy does not establish an exclusion from all others.

5. What changed, and what remains to verify

The 2026 Acts need provision-by-provision commencement checks. An enacted measure can have a future application date. Examples relevant to this chapter include:

• Individual income-tax bands changed for the income year beginning 1 July 2026. The domestic-dividend exemption in Sub-part B item 1 remains; distinguish it from the deleted emoluments item in Sub-part A.
• The Finance Act provides for a possible additional captive-insurance exemption period for qualifying licences issued before 19 June 2026. It is not an automatic extra holiday for every captive.
• The newly enacted general-insurance premium tax starts on 1 January 2027. It is not a current charge at this course’s cut-off.
• Amendments to the global-business-entity definition and some schedule provisions have separate future commencement rules. Do not apply the entire amending section on one assumed date.
• The Economic and Financial Measures Act inserts the Private Wealth Management framework. Operational rules, commencement and licence availability need separate confirmation.

There is also a directory discrepancy: the FSC web list includes a digital-asset custodian category not found in the replacement July 2026 licensing-fee schedule reviewed. The library keeps that discrepancy visible. Historical Category 1 wording in the web directory is likewise labelled.

Read how the courses are written before using this trial as a research starting point. The library is an indexed route into the law, not a certification that every tax rule and permission has been exhaustively resolved.

Put it into practice

A founder proposes “a foundation with a GBC and a financial-services licence, paying 3%”. Your first response should be a fact-gathering exercise: identify the legal person and activity, check which permissions can apply, establish residence, classify each income stream, test relief and then review the other taxes and filings.

The strongest tax working paper makes its assumptions visible. It names the taxpayer, the provision, the date, the evidence and the points still requiring verification.