The Finance (Miscellaneous Provisions) Act 2018 is the blueprint for a major restructure in the jurisdiction covering corporate tax, personal tax, VAT, tax administration and regulatory changes.
The key changes include:
- The Category 1 Global Business Licence company (GBC1) will become the Global Business Licence company (GBL) from either July 1 2021, if their licence was issued on or before October 16 2017, and January 1 2019, if issued after.
- Category 2 Global Business Licence companies (GBC2) are being abolished and replaced by a new Authorised Company regime.
These reforms, which have some important dates approaching, are an opportunity for businesses with GBC1 and GBC2 companies within their corporate structures to undertake a review and determine if restructuring action needs to be taken.
Key elements to these changes include:
- The 80 per cent foreign tax credit the GBC1 received on its foreign income will be abolished on January 2 1019
- The new GBL will receive an exemption of 80 per cent in respect of its investment income but not its trading income
- The GBL will have to meet the Mauritian substance requirements (having Mauritian directors, accounts, premises etc) and these are expected to be tightened
- GBC1s and GBC2s with licences granted on or before October 16 2017 are grandfathered until June 30 2021 and those with licenses after, until December 31 2018
- An Authorised Company will not be able to access Mauritius' double taxation agreement network as it will be considered non-resident in Mauritius but it will need to make a return of income to the Mauritius Revenue Authority within six months of its year end.
How ILS World can help:
ILS World is very experienced in re-domiciling companies and whether your world is onshore, offshore or both, our company formation and management services can help you achieve your objectives with tax efficiency and cost effectiveness.
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Please note: ILS World does not offer tax advice and would therefore recommend you obtain your own tax advice. If you require an introduction to a tax adviser we would be happy to assist.