On this page
- What each vehicle actually is
- Offshore company vs US LLC: side-by-side comparison
- Bank accounts
- Non-resident tax: how the two differ
- Payment platforms and marketplaces
- Compliance and running costs
- Which one fits? A decision path
- A route to a Mauritius company if you go that way
- Who tends to lean which way
- FAQ
Online entrepreneurs outside the United States often end up weighing two familiar vehicles: a US limited liability company, typically formed in a state such as Wyoming, and a Mauritius Authorised Company. Both can be owned by a foreigner, both can be formed remotely, and both are marketed to people selling digital products, services or goods across borders. They are nevertheless built on very different legal foundations, and the differences show up mostly in three places: the bank account, the tax treatment of a non-resident owner, and how payment platforms react to the entity.
This page puts the two side by side. It does not say which is better, because the answer depends on where you live, what you sell and who your customers are. If you already know you want a Mauritius structure, the overview of the Authorised Company is the better starting point.
What each vehicle actually is
The US LLC
A US LLC is a state-law entity. Its tax treatment is decided mainly by federal rules and by the owner's own situation, not by the state of formation. A Wyoming LLC, a Delaware LLC and a New Mexico LLC differ in filing costs and privacy practices, but the federal tax logic is broadly shared. For a single non-US owner, the LLC is commonly treated as transparent for US federal purposes, which means the entity itself is not the taxpayer in the way a company is. Whether that suits you depends on the nature of your income and on what your home country does with the structure. A US-based adviser is the right person to confirm the position.
The Mauritius Authorised Company
An Authorised Company is a Mauritius-incorporated company authorised under section 71A of the Financial Services Act 2007. The law requires its central management and control to sit outside Mauritius, it needs a Mauritius registered agent that is a FSC-licensed corporate service provider (Management Licence), and it cannot carry on the activities listed in the Fourth Schedule of that Act. The official registry page for incorporation states that it requires one director, who does not need to be resident, and a registered agent. For the full legal profile, see the Authorised Company and the FSC.
An Authorised Company is also a "global business entity" for the purposes of the Income Tax Act, a category it shares with the Global Business Licence company. That label matters for some rules, such as the Alternative Minimum Tax, which does not apply to global business entities. The difference between the two Mauritius vehicles is handled elsewhere on the site and is not repeated here.
Offshore company vs US LLC: side-by-side comparison
| Criterion | Mauritius Authorised Company | US LLC (for example Wyoming) |
|---|---|---|
| Legal basis | Companies Act 2001 and Financial Services Act 2007, s. 71A | State LLC statute plus US federal tax rules |
| Regulator involved | FSC authorisation, Registrar of Companies | State filing office; no licensing body for the LLC itself |
| Management location | Central management and control must be outside Mauritius | No such requirement; US tax status depends on the owner |
| Professional provider | Registered agent that is a FSC-licensed corporate service provider (Management Licence) | A state-registered agent is required; the role is narrower |
| Bank account | Mauritius or foreign bank; scrutiny of substance and activity | US bank or fintech account; scrutiny of identity and location |
| Treatment of a non-resident owner | Governed by Mauritius law and by the owner's home rules | Governed by US federal rules and by the owner's home rules |
| Payment platform acceptance | Often reviewed case by case | Generally easier to onboard, particularly with US platforms |
| Beneficial ownership | Recorded with the Registrar; not described as public | Disclosure rules differ by state and federal regime |
| Perception by clients | Varies by the client's country | Familiar to most online platforms and marketplaces |
The table is a summary, not a recommendation. Each row has qualifications that the sections below explain.
Bank accounts
Banking is where most owners feel the difference first. A US LLC can often open an account with a US-based provider, including digital banks that serve non-residents, but the owner is still asked who they are, where they live and what the business does. An Authorised Company faces similar questions and more of them, since it is a foreign-owned company with its management outside Mauritius. Banks generally want to understand the commercial reason for the structure, the source of funds and the real activity.
The identity of the beneficial owner is a constant in Mauritius. Every Mauritius company must identify its beneficial owner and any nominee at all times and record them in a separate register, with the owner's full name and residential address, identity or passport number, nationality and the holding structure that leads to the ultimate beneficial owner (Companies Act 2001, section 91(3A)). The Registrar of Companies keeps a Beneficial Ownership Register that competent authorities can consult; the Companies Act does not describe it as public. Whether the owner stays private deserves its own reading.
For the practical options and reasons for refusal, read banking options for an offshore company and why banks refuse offshore company accounts. Reporting also plays a part: under the Common Reporting Standard, Mauritius financial institutions report accounts held by non-residents to the MRA each year, for exchange with treaty partners.
Non-resident tax: how the two differ
Mauritius
The standard corporate income tax rate in Mauritius is 15% of chargeable income. A company is tax resident in Mauritius if it is incorporated there or if its central management and control are there (section 73 of the Income Tax Act). A company incorporated in Mauritius but centrally managed and controlled outside the country is treated as non-resident under section 73A, yet it must still file an income tax return under section 116. A Corporate Climate Responsibility Levy of 2% of chargeable income also applies to companies, for the tax year beginning 1 July 2024 and each later year (section 50O).
Those headline figures say little on their own. How an Authorised Company is actually taxed depends on its facts and on the conditions attached to each relief. The page on Authorised Company taxation sets out the framework, and the Mauritius non-resident company page explains the status.
The United States
For a US LLC with a single non-US owner, the question is usually whether the LLC has US-source income or a US trade or business. Outside the United States, the owner's home country decides how the LLC is treated, and some countries treat it as a company, others look through it. That can create results the owner did not expect. Reading the home-country rules is not optional, whichever vehicle is chosen. For readers in particular countries, the pages on UK residents and Indian residents are good examples of how local rules reshape the analysis.
Home-country rules apply either way
An offshore structure does not remove the owner's own tax position. If you manage and control the company from your home country, your tax authority may regard it as resident there, and controlled foreign company rules may attribute its income to you. The pages on permanent establishment risk and controlled foreign company rules cover those risks, and the self-check on tax exposure is a useful first filter.
Payment platforms and marketplaces
Payment processors, marketplaces and app stores usually ask for the same documents: proof of incorporation, proof of address, proof of the owner's identity and a bank account in the company's name. In practice, platforms built around the US system tend to be more familiar with US LLCs, and onboarding is often smoother. An Authorised Company may meet a longer review, additional questions about substance, or restrictions in specific product categories.
Neither outcome is guaranteed, and platform policies change. Before forming either vehicle, check the current terms of the platform you rely on and confirm that the country of incorporation is supported. The guide to taking online payments with an offshore company lists what reviewers typically look for, and multi-currency accounts for an offshore company covers holding receipts in several currencies.
Customer perception is a related but separate point. How clients and suppliers perceive an offshore company is worth reading before you rely on the Mauritius address in your invoices.
Compliance and running costs
Neither structure is passive. A US LLC carries state annual filings and US federal reporting obligations that depend on its ownership and activity. An Authorised Company has its own recurring duties: the registered agent handles filings under the Financial Services Act, the Income Tax Act and the Companies Act, relays communications with the FSC, the MRA and the Registrar, applies AML/CFT measures and keeps the records (section 71A(8)). The company must file an income tax return whether or not it is taxable, within the statutory deadline.
For the 2026-27 renewal cycle, the FSC moved the deadline for annual fee payment to 30 September 2026, with payment through the FSC One platform. The fee schedule itself was replaced by the Financial Services (Consolidated Licensing and Fees) (Amendment) Rules 2026 (Government Notice No. 119 of 2026), in force since 1 July 2026. Read annual fees and annual obligations for the detail rather than relying on a generalised cost comparison.
Operating without authorisation is an offence: a company that acts as an Authorised Company without authorisation faces a fine of up to MUR 1 000 000 (section 71A(12)).
Which one fits? A decision path
The tree is deliberately cautious. It does not replace advice on your own facts.
A route to a Mauritius company if you go that way
- Test your platforms and bank
Confirm that your payment processor and bank will accept a Mauritius entity.
- Check your home-country position
Ask a local adviser how your tax authority will treat the company.
- Choose a licensed provider
Verify that the registered agent holds the right FSC licence.
- Submit the application
The provider files the application and the FSC reviews it once complete.
- Open the account and set up routines
Start accounting records and a yearly calendar.
The step-by-step guide to opening an offshore company goes through each stage. When the FSC receives a complete application, it must decide within 10 working days (section 17B, applied to Authorised Company applications by section 17C). Preparing the file properly beforehand usually matters more than that statutory period. To verify a provider, use the FSC licence check.
Who tends to lean which way
Nothing here is a rule, but a few patterns recur:
- Sellers focused on US platforms and US customers often start with a US LLC because onboarding is usually smoother.
- Owners with customers in Europe, Africa or Asia sometimes find that a Mauritius structure fits better, particularly where they can actually run the business from outside Mauritius.
- Owners living in countries with strict foreign-company rules need a home-country opinion before any choice.
- Owners who live in Mauritius should read living in Mauritius while owning an Authorised Company, because the management-location condition changes the picture.
For concrete scenarios, the pages on e-commerce through an offshore company, software and SaaS businesses and the online business hub show how each type of operation fares.
If your situation is specific, send a short description through the contact form and the request will be relayed to a FSC-licensed provider.
FAQ
Is a Wyoming LLC an offshore company?
Not in the Mauritius sense. A Wyoming LLC is a domestic US entity, even when its owner lives abroad. "Offshore" is a description of where the owner lives relative to the entity, not a legal category. Whether the structure is advantageous depends on your home-country rules and the nature of your income.
Is it easier to open a bank account for a US LLC than for a Mauritius company?
Often it is easier to find a provider that will onboard a US LLC, since many providers are built around the US system. That is a tendency, not a guarantee. Both vehicles face identity and activity checks, and the outcome depends on the provider and on your profile.
Can a US LLC owner living outside the US avoid US tax?
That depends on the type of income, whether the LLC has a US trade or business, and the rules applied by your own country. This site cannot give a US tax opinion. A qualified adviser should confirm the position before you form the LLC.
Does a Mauritius Authorised Company file a tax return?
Yes. A Mauritius company that is treated as non-resident because it is managed and controlled outside the country must still file a return under section 116 of the Income Tax Act. See the yearly checklist for the routine.
Can I compare the Mauritius company with a UK or BVI company as well?
Yes. The site has separate comparisons for the UK limited company and the BVI company.
Are the owners of both vehicles private?
Neither vehicle guarantees secrecy. Mauritius records beneficial owners in a register that is not described as public, but authorities can access it. US rules on beneficial ownership are evolving. Treat privacy as a limited benefit, never a promise.
Sources
- Financial Services Act 2007, consolidated version — Financial Services Commission
- Financial Services (Consolidated Licensing and Fees) (Amendment) Rules 2026 — Financial Services Commission
- Circular letter on annual fee payment deadline — Financial Services Commission
- Income Tax Act, consolidated — Mauritius Revenue Authority
- Common Reporting Standard notice — Mauritius Revenue Authority
- Companies Act 2001, updated 15 May 2026 — Corporate and Business Registration Department
- Incorporation of a domestic company — Corporate and Business Registration Department