Sunibel Corporate Services

Global Business sector reforms: Are you ready for 1st July 2021?

Major tax changes brought by the Finance Act 2018 to the global business regime will take effect as from 1st July 2021. The timeline below depicts the main changes:

Grandfathering period Mauritius - Sunibel Corporate Services Ltd


What is changing?

As from 1st July 2021, grandfathered companies holding Global Business Licence Category 1 will be converted into Global Business Licence (GBL) companies and companies holding Category 2 Global Business Licences (GBL2) will be phased out.

Therefore, by 30th June 2021, companies holding a GBL2 since or before 16th October 2017 will have to:

As from 1st July 2021, companies holding a GBL (since or before 16th October 2017) will have to observe the new substance requirements by carrying out their Core Income Generating Activities (“CIGA”) in or from Mauritius.

The deemed 80% foreign tax credit will no longer be available, meeting the new substance requirements is crucial for a GBL company to be eligible for the 80% partial tax exemption, which is applicable on specific types of income including foreign dividend and interest. From 1st July 2021, other types of income such as service fees and management fees will be subject to a 15% tax.

The table below highlights the types of income/activities on which a partial exemption is available:

 Before 1st July 2021 After 1st July 2021
All types of income
  • Foreign source dividend provided that it has not been allowed as a deduction in the country of source
  • Foreign source interest income
  • Profit attributable to a permanent establishment which a resident company has in a foreign country
  • Income derived:
    • by a collective investment scheme (CIS), closed end fund, CIS manager, CIS administrator, investment adviser or asset manager; or
    • by companies engaged in ship and aircraft leasing


How can Sunibel Corporate Services help you?

  • Optimisation of your situation if you have a Mauritius structure and would like to explore other jurisdiction like United Arab Emirates (UAE);
  • Assessment on your current structure when converting into an Authorised Company, Global Business Licence company or other jurisdiction solutions; and
  • Assessment on whether you meet the new substance requirements.