Limits of an Authorised Company

Any honest review of authorised company limitations starts with one point: the structure was designed for a specific profile, a company owned by non-citizens, run from abroad and earning its income outside Mauritius. Step outside that profile and the structure either stops working or stops being lawful. This guide sets out the constraints, the disadvantages that follow from them, and the situations where another route is the better fit.

It is general information, not advice. Whether a given limit matters depends on where you live, what you sell and who you sell to, so a personal analysis by a qualified adviser is the right next step.

The legal frame behind every limit

Authorised Companies exist under section 71A of the Financial Services Act 2007 (the FSA). The company is incorporated under the Companies Act 2001 and then needs an authorisation from the Financial Services Commission (FSC). The FSA ties that authorisation to three conditions at once: a majority of shares or voting rights held or controlled by a non-citizen of Mauritius, business conducted mainly outside Mauritius, and central management and control located outside Mauritius.

Each of those conditions is also a limit. Change the ownership, bring the business home or move the decision-making to the island, and the company no longer matches what the authorisation was granted for. The requirements for an Authorised Company page covers the entry conditions in full; here the focus is on what they rule out.

No treaty access: the first disadvantage to understand

The most common surprise is the absence of treaty access. Under section 73A of the Income Tax Act, a company incorporated in Mauritius but centrally managed and controlled abroad is treated as non-resident. It must still file an income tax return under section 116.

Double tax treaties generally protect residents of a contracting state. A company that Mauritian law itself treats as non-resident does not sit comfortably in that logic. The Income Tax Act does provide a Tax Residence Certificate, issued by the Director-General of the Mauritius Revenue Authority (MRA) to a person who wants to be certified as resident of Mauritius, but it is a residence document, and the premise of an Authorised Company is that central management sits elsewhere.

The practical consequences:

• Payments received from a client's country may suffer withholding tax at the domestic rate, with no treaty rate to reduce it.
• A foreign tax authority may refuse to treat the company as a Mauritian tax resident.
• Any claim to treaty relief would depend on facts, such as where management really sits, that cut against the purpose of the structure.

The detail of individual treaties belongs elsewhere. For the withholding side of the question, see withholding tax on payments received.

No trade in Mauritius

An Authorised Company must conduct its business mainly outside Mauritius. It is not a vehicle for selling to Mauritian customers, opening a shop or running a local service. The guide on doing business in Mauritius explains the boundaries in more detail.

Some limited local dealings are tolerated. Section 71A(13) of the FSA says an Authorised Company is deemed to conduct business outside Mauritius even if it carries out the operations referred to in section 73(1)(c) to (f). For a Global Business Licence holder, the same Act lists operations of that kind, including a rupee bank account for day-to-day local expenses, holding or disposing of immovable property in Mauritius (subject to the Non-Citizens (Property Restrictions) Act) and investments in securities listed on an exchange licensed under the Securities Act 2005. These are exceptions for housekeeping, not a licence to trade at home.

Trading without the right authorisation is an offence. The FSA provides a fine of up to MUR 1,000,000 for a company operating as an Authorised Company without authorisation.

Activities an Authorised Company cannot carry on

Unless the FSC Rules provide otherwise, an Authorised Company may not carry on the five activity categories of the Fourth Schedule of the FSA:

1. banking;
2. managing or administering a collective investment fund or scheme as a professional;
3. financial services;
4. providing registered office, nominee, director or secretarial services to companies;
5. professional trusteeship.

In practice this excludes anything resembling a financial business. A company that wants to hold client money, pool investors' funds or advise on investments is outside the structure. The related question of what business an Authorised Company can run lists the permitted side. Crypto and digital-asset activity raises its own regulatory issues, covered under crypto and digital asset businesses.

Mandatory local service provider

You cannot run an Authorised Company without a local intermediary. The company must have a registered agent in Mauritius at all times, and that agent must be an FSC-licensed corporate service provider (Management Licence). The application for authorisation itself is filed through such a provider.

The agent's duties under section 71A(8) of the FSA include filing the documents required under the FSA, the Income Tax Act or the Companies Act, passing on communications with the FSC, the MRA and the Registrar, carrying out anti-money laundering and countering the financing of terrorism (AML/CFT) measures, and keeping records such as minutes, resolutions and transaction documents.

This is a limit on independence as much as a safeguard. You cannot self-administer the company, and changing provider triggers a fee fixed by the FSC Rules, as the FSA has provided since 1 August 2024. The role is explained in the corporate service provider behind your company.

Running costs and annual filings

An Authorised Company is cheap to hold only in comparison with larger structures. Under the Financial Services (Consolidated Licensing and Fees) (Amendment) Rules 2026, in force since 1 July 2026, the authorisation carries a processing fee of USD 600 and an annual fee of USD 1,400. The annual fee excludes the annual registration fee of USD 65 (or another amount set by the Registrar of Companies) payable to the Registrar. For the 2026-27 renewal cycle the FSC extended the payment deadline to 30 September 2026.

The first annual fee is pro-rated by the quarter in which authorisation is granted, from USD 1,400 for July to September down to USD 350 for April to June. Service provider charges come on top and vary by provider.

The company must also file a financial summary with the FSC every year, no later than six months after its financial year ends, and a tax return under section 116 of the Income Tax Act, even if no tax is due. See annual fees and the yearly checklist.

Banking friction

Banking is where theory meets practice. The legal structure does not guarantee an account anywhere. Banks run their own risk assessments, and an offshore-style company with owners abroad, clients abroad and no local operations often triggers extra due diligence, longer onboarding or refusal.

Points that commonly cause friction:

• a business model the bank finds hard to verify;
• owners resident in countries the bank views as higher risk;
• limited documentation on the origin of funds;
• payment flows that do not match the declared activity.

Banks also differ in what they accept from a company that has no premises, staff or physical presence in the country where the account is opened. The pages on why banks refuse offshore company accounts and banking options look at how applicants prepare.

One contrast is worth noting. A Global Business Licence holder has to keep its main bank account in Mauritius, and from 1 September 2026 must operate its accounts under a signatory arrangement that follows FSC guidelines. Those are conditions of a different licence, mentioned only to show that banking rules differ between the two structures.

Reputational limits

An Authorised Company is a legitimate, regulated entity, but perception does not always follow the legal position. Some clients, marketplaces and payment platforms are cautious about companies labelled offshore. They may ask for additional documents, decline onboarding or apply stricter terms.

Privacy has limits as well. Every Mauritian company must identify its beneficial owner at all times and record the details in a separate register: full name and residential address, national identity or passport number, nationality and the ownership chain to the ultimate beneficial owner (Companies Act 2001, section 91(3A)). The Registrar keeps a Beneficial Ownership Register accessible to competent authorities and prescribed public authorities. The Companies Act does not describe it as a public register, but it is not secret from regulators and banks. See owner privacy for the full picture.

Your own tax authority is a separate matter. An Authorised Company does not remove the owner's obligations at home. Controlled foreign company rules, permanent establishment risk and personal taxation of distributions can all apply, depending on where you live. Start with the guides on home-country taxation of the owner and permanent establishment risk.

Limits summarised

When these limits point to another structure

The limits above are not defects to be worked around. They are signs that the structure fits some situations and not others. It tends to be a poor fit if you want to sell to Mauritian customers, need treaty protection on income received, plan to run a regulated financial business, or want to be physically managed from the island. A company with its management in Mauritius falls under a different licensing regime, which other resources cover, and the question of when to move up is addressed in when an Authorised Company is no longer enough.

If you are still deciding, the checklist before you start is a sensible next step. If you want your situation reviewed by a licensed provider, use the form on the contact page.