App and Game Developers: Structuring Revenue Offshore

A mobile app developer offshore company is, in Mauritius, usually an Authorised Company: a company incorporated under the Companies Act that is owned and controlled from outside the country and earns its income mainly abroad. For a developer whose revenue arrives from app stores in many countries, that profile can fit well. It is not automatic, though, and it is not a tax shelter. This page explains how store payouts reach such a company, what the tax forms are for, how the rights to the app sit in the structure, and where the rules draw a line.

It is general information. The right answer for a given developer depends on where they live, where they work and what the stores ask for.

Why developers look at this structure

Most indie developers start as individuals. Store payouts go to a personal bank account, the income is declared at home, and the developer is personally liable for anything that goes wrong. A company changes three things:

• Who the store pays. The payee becomes a legal entity, not a person.
• Who owns the app. The company holds the code, the brand and the contracts, which makes a later sale or a new co-founder simpler.
• Who is liable. Contracts, refunds and disputes sit with the company.

Developers who build mobile apps and games often add one more reason: revenue comes in several currencies from many countries, and a single company account is easier to reconcile than a personal one. The banking and multi-currency side needs care, because banks look closely at this type of income.

What the law requires of an Authorised Company

Under the Financial Services Act (FSA), a company incorporated under the Companies Act must apply to the Financial Services Commission (FSC) for authorisation as an Authorised Company where:

• a majority of its shares or voting rights is held or controlled by a person who is not a Mauritian citizen,
• it conducts its business mainly outside Mauritius, and
• its central management and control sit outside Mauritius (section 71A(1) FSA).

The Income Tax Act then treats a company incorporated in Mauritius as non-resident if it is centrally managed and controlled from outside Mauritius (section 73A). It must still file an income tax return under section 116. A company that operates as an Authorised Company without authorisation commits an offence punishable by a fine of up to MUR 1,000,000.

The Authorised Company must also have a Mauritian registered agent, which is an FSC-licensed corporate service provider (Management Licence). Among other things, that agent files the returns and documents required by the FSA, the Income Tax Act or the Companies Act, relays communications with the FSC, the Mauritius Revenue Authority (MRA) and the Registrar, carries out anti-money laundering and countering the financing of terrorism (AML/CFT) measures, and keeps the records. For the full definition, see Authorised Company in Mauritius.

How app store payouts reach the company

The mechanics are the same whatever the store. The company is the contracting party, the store pays the company, and the money lands in a business account in the company's name.

Two practical points follow from this flow.

First, the store account must be opened in the company's name from the start. Moving an existing personal developer account to a company later is sometimes possible, sometimes not, and the store's rules decide, not Mauritius law. Check the store's current process before you incorporate if you already have apps live.

Second, the bank account matters as much as the company. A store will only pay to an account whose holder name matches the account registered with it. The reasons banks hesitate are covered in why banks refuse offshore company accounts.

Tax forms and what they are really for

Stores that pay developers across borders ask for tax information. The details differ by store and change over time, but the logic is stable:

• Tax residence. The store wants to know which country the payee is tax resident in. For an Authorised Company that is managed from abroad, the answer is a question of fact: the Income Tax Act says a company incorporated in Mauritius but centrally managed and controlled abroad is treated as non-resident (section 73A), whereas a company with central management and control in Mauritius is tax resident there (section 73).
• Entity type and ownership. Stores usually ask whether the payee is a company, who owns it and sometimes who the beneficial owner is.
• Treaty claims. Forms often offer a reduced withholding rate if a tax treaty applies. An Authorised Company is not a regular treaty beneficiary, so do not assume a reduced rate. Whether any tax is withheld at source depends on the paying country's own rules. See withholding tax on payments received.

Answer these forms accurately. A form that overstates residence or ownership can lead to wrong withholding, frozen payouts or an account closure, and it is the company, not the store, that carries that risk. If the form asks where the company is managed, the honest answer must match where the decisions are actually taken. That is also why managing the company from abroad is a matter of substance, not wording.

Beneficial ownership information

Every Mauritian company must permanently identify its beneficial owner and any nominee, and record them in a separate register: full name and residential address, national identity or passport number, nationality, and the ownership chain up to the ultimate beneficial owner (Companies Act 2001, section 91(3A)). The Registrar of Companies keeps a Beneficial Ownership Register that is accessible to competent authorities and other prescribed public authorities; the Companies Act does not describe it as public. Expect a store, a bank or a payment provider to ask for the same information.

Where the rights to the app sit

The company should be the owner of the app code, name, graphics, music and any game assets. That rarely happens by itself. Three situations are common:

Whether an assignment is valid and effective depends on the law of the country of the author and of the work, so have it reviewed. The wider question of holding intellectual property in a company has its own page: holding intellectual property in an offshore company. Subscription software is treated in software and SaaS businesses.

Royalties and licensing

Some developers license the app to an operating entity and take royalties. Royalties paid to a non-resident by a Mauritian company out of foreign-source income are exempt (Second Schedule, Part II, Sub-part A, item 5). That rule concerns payments made by the company. It does not tell you how the developer is taxed at home on what they receive from it.

Tax treatment: what the sources support

The standard corporate tax rate in Mauritius is 15% of taxable income (First Schedule, Part IV of the Income Tax Act). Special regimes exist, so the standard rate is not the whole picture, and how it applies to an Authorised Company is covered on the Authorised Company taxation page. The Income Tax Act defines a "global business entity" as including both a Global Business Licence holder and a company authorised under section 71A of the FSA, which matters for several rules.

A few levies and rules are worth knowing exist:

• The Corporate Climate Responsibility Levy is 2% of chargeable income, from the tax year beginning 1 July 2024 (section 50O). No levy is due where turnover for the year does not exceed MUR 50 million.
• The Corporate Social Responsibility rule requires a company to set up a CSR fund equal to 2% of the previous year's taxable income (section 50L).
• The Alternative Minimum Tax of section 44A does not apply to a global business entity, which includes an Authorised Company. It applies from the tax year beginning 1 July 2026 to a limited list of sectors.
• The corporate Fair Share Contribution applies to companies whose taxable income exceeds MUR 24 million in the year, on income received from 1 July 2025 to 30 June 2028. Since the Finance Act 2026, the turnover criterion has been removed.

Do not read this as a promise of low tax. The facts above describe Mauritian rules. They say nothing about what the developer's home country will tax, and that is usually the decisive question.

The limits that matter most

Home-country tax

An Authorised Company has no tax treaty network to lean on, and the owner's home country may tax the company's profits or the owner personally. Controlled foreign company rules, place-of-management tests and permanent establishment rules can all apply. Read controlled foreign company rules and permanent establishment risk before choosing a structure. Paying yourself from the company raises its own questions, covered in paying yourself from an offshore company.

Working from Mauritius

The structure depends on central management and control being outside Mauritius. A developer who relocates to Mauritius and runs the company from there changes the analysis completely. This guide does not cover that case.

Excluded activities

An Authorised Company cannot carry on the activities listed in the Fourth Schedule of the FSA. Most games and utility apps are far from that list. Apps that handle payments, lend, offer investment services or deal in digital assets are a different matter and call for a licensing review first.

Store rules and local law

Each store has its own terms on who may hold an account, which countries it pays in and what it withholds. The company must also meet consumer, data protection and sales tax rules in the markets where it sells. Stores often act as the seller of record and handle consumption taxes on the developer's behalf, but that is a feature of their terms, not a rule of Mauritian law.

A short decision aid

Keeping the company in good standing

Once it exists, the company has recurring duties. Every company, taxable or not, files its income tax return with the Director-General within 6 months after the end of the month in which its financial year closes (section 116(1) Income Tax Act). Filing and payment are electronic. Annual FSC fees are paid through the FSC One platform, including by direct debit or from the deposit account of the corporate service provider. The Financial Services (Consolidated Licensing and Fees) (Amendment) Rules 2026 (Government Notice No. 119 of 2026) replaced the fee schedule from 1 July 2026. For the cycle 2026-27, the FSC moved the payment deadline to 30 September 2026.

The yearly routine is laid out in annual obligations of an Authorised Company. You also need accounting records that show how each store payout became revenue, net of fees.

What to ask before you commit

• Which store accounts will move to the company, and does each store accept that?
• Who owns each app today, and is there a written assignment?
• Where will decisions be taken, and by whom?
• How will the company's profit reach me, and how is it taxed where I live?
• Does the registered agent hold a valid licence? The FSC licence check shows how.

To ask a licensed provider about setting up, use the contact form.