Authorised Company Taxation in Mauritius

Authorised company Mauritius tax is easily misunderstood, because the label "offshore" suggests a single rule that applies to everyone. There is no such rule. The company's position in Mauritius is set by the Income Tax Act and the Financial Services Act. The tax position of the person who owns it is set by the law of the country where that person lives. This page explains authorised company taxation in Mauritius, separates what the company itself pays and files from what falls on its owner, and shows where the genuine risk usually sits.

It is general information, not advice. Almost every point below depends on where the owner lives, where decisions are taken and what the company actually does. A qualified adviser should confirm the position before you rely on it.

The short answer

An Authorised Company is a Mauritius-incorporated company that is owned by non-citizens, trades mainly outside Mauritius and is managed and controlled from outside Mauritius. In Mauritius it carries a regulatory cost (authorisation and annual fees), a filing duty (an annual return to the tax authority and a financial summary to the regulator) and an obligation to keep proper records through a local agent.

What it does not do is remove the owner's own tax obligations. If you live in a country that taxes residents on worldwide income, or that attributes the profits of a controlled foreign company to its owner, the Mauritius company does not change that. For most readers the home-country analysis matters more than anything in the Mauritian statute book.

How the Mauritian tax code classifies an Authorised Company

The Income Tax Act defines a "global business entity" to include a company holding a Global Business Licence from the FSC and a company authorised under section 71A of the Financial Services Act, which is the Authorised Company. The two share a tax-law label but are different legal vehicles. The Global Business Corporation is governed by section 71 of the Financial Services Act 2007, and the Authorised Company by section 71A of the same Act. The consolidated text published by the FSC is current to 1 September 2026.

That classification matters in practice because some Mauritian rules are written to exclude global business entities. The Alternative Minimum Tax is the clearest example (see below).

For the question of how a licensed Global Business Corporation is taxed, and for the treaty network, other resources cover those topics. This page concentrates on the Authorised Company.

Tax residence: where the company is "from"

Tax residence is the starting point for every other question. Under section 73(1)(b) of the Income Tax Act, a company is resident in Mauritius for tax purposes if it is incorporated in Mauritius or if its central management and control is in Mauritius.

An Authorised Company is incorporated in Mauritius, so on that limb alone it would be resident. Section 73A changes the result. A company incorporated in Mauritius is treated as non-resident if it is centrally managed and controlled outside Mauritius. The same section states that it must nevertheless file an income tax return under section 116.

Two consequences follow:

• The status depends on facts, not on the paperwork. The Financial Services Act requires an Authorised Company to have its central management and control outside Mauritius (section 71A(1)). If board decisions are in fact taken in Mauritius, the company's position is at risk on both the regulatory and the tax side.
• Non-resident treatment does not mean no filing. The return is still due. See managing an Authorised Company from abroad for what "managed and controlled outside Mauritius" looks like in day-to-day practice.

What the company does and does not pay in Mauritius

The standard rate and why it is not the whole story

The standard corporate income tax rate is 15% of chargeable income. It is set by Part IV of the First Schedule to the Income Tax Act 1995 (consolidated up to the Finance Act 2026), and section 44 applies it to companies generally, subject to the special regimes in sections 44B and 44C. The rate has applied for income years starting on or after 1 July 2010.

It would be wrong to read that figure as the Authorised Company's bill. Whether any Mauritian income tax is charged depends on the company's residence status, the source of its income and the exemptions that may apply. A non-resident company does not simply pay 15% on all of its receipts, and it is equally wrong to assume it pays nothing. The right approach is to treat the question as one for a Mauritian tax adviser, using the company's actual facts.

The Alternative Minimum Tax does not apply

Section 44A of the Income Tax Act provides that where a company's normal tax is below 10% of its adjusted book profit, the tax payable equals 10% of that adjusted book profit. It applies from the income year beginning on 1 July 2026.

It targets licensed hotels, insurers, financial intermediaries, property companies and telecommunications companies. It does not apply to a global business entity, which means it covers neither a Global Business Corporation nor an Authorised Company. It also does not apply to entities exempt under Part I of the Second Schedule.

Dividends and foreign income

The Second Schedule contains exemption rules that readers often meet in the marketing of Mauritian structures. Two are worth understanding, mainly so that you can see their conditions.

• Foreign-source dividends received by a company can be 80% exempt, but only if the dividend was not deducted in the source country and the company meets the substance requirements for its activities set out in the regulations. The same 80% treatment covers interest (item 7) and income from leasing ships, aircraft and locomotives and trains (item 42), again under substance conditions.
• Dividends paid by a Mauritius-resident company are exempt from income tax for the recipient, with no withholding tax on them (Second Schedule, Part II, Sub-part B, item 1).

These provisions are written with substance and conditions attached. An Authorised Company is defined by being managed from outside Mauritius, which sits uneasily with a substance-based exemption. Do not assume that either rule applies to your company without written advice. For the practical side of getting money out of the company, see paying yourself from an offshore company.

Foreign tax credit

Section 77 of the Income Tax Act gives a credit for foreign tax paid on income taxed abroad, set against the Mauritian tax due on that income. No credit is given on foreign-source income for which a partial exemption under Part II of the Second Schedule has been claimed. In other words, you cannot take both the exemption and the credit on the same income.

What the company must do each year

A low or nil tax charge is not the same as a low administrative burden. The recurring duties are well defined.

The income tax return

Every company, whether or not it is taxable, must file its return with the Director-General no later than 6 months after the end of the month in which its financial year closes (section 116(1)). For a year ending in June, the deadline is 2 working days before the end of December (section 116(2)). For a year ending in December, it is 2 working days before the end of June (section 116(2C)). Filing and payment are electronic.

The financial summary

Separately, an Authorised Company must file with the FSC each year, within 6 months of the end of its financial year, a financial summary in the form set out in the Ninth Schedule to the Companies Act, or other documents specified by the FSC Rules (section 71A(10) of the Financial Services Act).

The registered agent

An Authorised Company must have a registered agent in Mauritius at all times, and that agent must be an FSC-licensed corporate service provider (Management Licence) (section 71A(7)(a)). Under section 71A(8) the agent handles, among other things:

• filing the returns and documents required by the Financial Services Act, the Income Tax Act or the Companies Act;
• passing on communications from the FSC, the Mauritius Revenue Authority and the Registrar of Companies;
• anti-money-laundering and counter-terrorist-financing measures;
• keeping the records, including minutes, resolutions and transaction documents.

If you change agent, the application must be accompanied by the fee set by the FSC Rules (section 71A(7)(b), in force since 1 August 2024).

The annual obligations of an Authorised Company are covered on their own page, and the yearly checklist turns them into a calendar.

What it costs: fees are the real Mauritian charge

For many owners the Mauritian cost of an Authorised Company is a regulatory fee, not an income tax. The Financial Services (Consolidated Licensing and Fees) (Amendment) Rules 2026 (Government Notice No. 119 of 2026) took effect on 1 July 2026 and replaced the previous fee schedule.

The first annual fee is prorated according to the quarter in which the authorisation is granted: 1,400 USD (July to September), 1,050 USD (October to December), 700 USD (January to March) and 350 USD (April to June).

For the 2026-27 renewal cycle the FSC moved the payment deadline to 30 September 2026. Payment is made through the FSC One platform, including by direct debit or from the deposit account of a licensed corporate service provider.

On the same scale, a Global Business Corporation pays 600 USD to process and then 2,600 USD a year, so the Authorised Company's annual fee is 1,200 USD lower. In its communiqué of 10 July 2026 the FSC said processing fees had not changed since the 2008 rules and annual fees had not been reviewed since 2019. It presented the reform as the implementation of a 2025/26 budget measure and justified the adjustment for Authorised Companies by their higher inherent risk profile.

The service provider also pays the FSC. A licensed corporate service provider acting as registered agent pays a variable fee that depends on how many Authorised Companies it administers at the end of the previous year. That cost is the provider's, but it can influence how providers price their services, which is one reason to compare quotes. The guide to annual fees breaks down what to expect.

Why the real tax question sits in the owner's country

Mauritius sets the framework for the company. It does not set the tax result for the person who owns and controls it. That result is decided by the owner's country of tax residence, and sometimes by the country of the customers or of the place where the work is done.

Owner residence

Most countries tax their residents on worldwide income. Profit that is earned by a company you own and then paid to you as dividends, salary or loan repayments is generally visible to your home tax authority at the point it reaches you. How the owner of an offshore company is taxed at home walks through the typical routes.

Controlled foreign company rules

Many countries have rules that attribute the profits of a foreign company controlled by their residents to those residents, whether or not the profits are distributed. If your home country has such rules, a low Mauritian charge can be neutralised at home. The controlled foreign company rules guide explains the mechanism and the questions to put to an adviser.

Permanent establishment

If you, an employee or an agent carry out the company's business from your home country in a way that creates a taxable presence there, the profits attributable to that presence can be taxed locally. This is a separate risk from the owner's own tax and is covered in permanent establishment risk.

Management and control

The same facts feed both the Mauritian and the home-country tests. A company whose directors are in practice in the owner's home country may be considered resident there, in addition to the question under section 73A about Mauritius. A company that is meant to be managed abroad but is run from a flat in Mauritius has the opposite problem.

A short self-test is available in Is your offshore structure exposed to tax risk?. It does not replace advice, but it helps you decide which questions to bring to a professional.

A Tax Residence Certificate for the company

A person who wishes to be certified as resident in Mauritius may apply to the Director-General of the Mauritius Revenue Authority for a Tax Residence Certificate. It must be issued within 7 days of the application, provided that the required return (section 112 or 116) has been filed and the service fee paid (section 73(2)-(3) of the Income Tax Act).

For an Authorised Company, which is managed from outside Mauritius, the question of whether such a certificate is appropriate or obtainable depends on the company's residence position under sections 73 and 73A. A counterparty or a bank that asks for one should be answered on the basis of advice, not on the assumption that the document is automatic.

Reporting and transparency

Taxation is not the only area where the company's profile matters. A Mauritian company must at all times identify its beneficial owner and, where relevant, any nominee, and record them in a separate register. The register holds the full name and residential address, the national identity or passport number, the nationality and the holding structure that identifies the ultimate beneficial owner (Companies Act 2001, section 91(3A), as updated on 15 May 2026).

The Registrar of Companies keeps a Beneficial Ownership Register that is open to the competent authorities and other prescribed public authorities. The Companies Act does not describe it as a public register. For a fuller answer, see whether the owner of an offshore company is private.

A company service provider is also a regulated profession under the anti-money-laundering legislation (FIAMLA schedule, line 12, with the Registrar of Companies as regulator), as are accountants, law firms, notaries and estate agents. In practice this means your provider will ask for identity documents and information about the source of funds, and a refusal to provide them ends the engagement.

Common misconceptions

Penalties and the cost of getting it wrong

Operating as an Authorised Company without authorisation is an offence. A company that carries on the business described in section 71(1) without a Global Business Licence commits an offence punishable by a fine of up to MUR 1,000,000, and the same penalty applies to a company that operates as an Authorised Company without authorisation (sections 71(5) and 71A(12) of the Financial Services Act).

On the fee side, the late-payment steps in the table above show how a missed deadline turns a 1,400 USD fee into a larger one. The practical conclusion is that a calendar kept by the provider, and checked by you, is cheaper than any correction.

An Authorised Company also cannot carry out the activities of the Fourth Schedule to the Financial Services Act unless the FSC Rules provide otherwise: banking; managing or administering a collective investment scheme or fund as a professional; financial services; corporate, nominee, director or secretarial services for companies; and professional trusteeship (section 71A(4)). It is deemed to carry on business outside Mauritius even if it performs the transactions in section 73(1)(c) to (f) of the Financial Services Act (section 71A(13)). See limits of an Authorised Company for the practical consequences.

Practical order of work

If you would like a licensed provider to look at your situation, you can use the contact form; the request is relayed to an FSC-licensed company.