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Collective Investment Schemes
Funds set up in Mauritius enjoy a low tax regime and have access to its network of double taxation agreements.

The following types of funds have been set up in Mauritius:

• Open ended/close ended portfolio funds
• Private equity/venture capital funds
• Hedge funds
• Debt funds
• Funds can be set up as a GBL1 company or a trust. In the case of a GBL1 fund, it may be in the form of a Protected Cell company governed by the Protected Cell Company Act 1999, as amended in 2001

Tax Treaties
Mauritius has focused the development of its Global Business centre on the use of its growing network of double taxation treaties for structuring investment abroad. So far Mauritius has ratified thirty treaties and is party to a series of treaties under negotiation. The treaties currently in force are with:

• Belgium
• Botswana
• Cyprus
• France
• Germany
• India
• Indonesia
• Italy
• Kuwait
• Lesotho
• Luxembourg
• Madagascar
• Malaysia
• Mozambique
• Namibia
• Nepal
• Oman 
• Pakistan
• People's Republic of China 
• Singapore
• South Africa
• Sri Lanka
• Swaziland
• Sweden
• Rwanda
• Thailand
• Uganda
• United Kingdom
• Zimbabwe

Tax Treaties - Eligible Entities
Tax treaty benefits are only available to resident entities or persons. Accordingly, a resident entity must be liable to tax in Mauritius under its laws by reason of its domicile, residence or criterion of a similar nature. Mauritius provides a wide range of resident entities and hybrid structures including the Global Business Company, the Trust and the Société. A foreign company including the Global Business Company may benefit from the tax treaty network. It is also possible for the Mauritian branch of a foreign company to access the tax treaties by satisfying the conditions of residence. These entities if wishing to avail of the benefits of a tax treaty must obtain a Tax Residence Certificate issued by the Commissioner of Income Tax in Mauritius.

Tax Treaties - Scope of Double Taxation Avoidance Treaties
All Mauritian double taxation avoidance treaties are based on the OECD Model Treaty of 1977. Under the post-independence treaties concluded so far, tax sparing is available. This means that where Mauritian source dividends are exempt from tax under the tax incentive provisions, the foreign investor is entitled to credit a notional amount of Mauritian tax against the tax payable (if any) in his country, thus reducing his domestic tax liability.

Foreign Tax Credit Mechanism
Regulations applicable to both offshore and onshore companies are:

• Foreign Tax Credit (FTC) is available in respect of foreign taxes paid (withholding and/or underlying taxes) irrespective of tax treaties
• Underlying Tax Credit (UTC) is available where shareholding is at least 5% direct or indirect
• Underlying Tax Credit (UTC) is extended to all previous tiers
• Tax sparing credit
• FTC computed by aggregating all foreign sources of income

Regulations applicable to Category 1 Global Business Licence companies only:

• 80% presumed foreign tax credit
• May compute FTC by using a mixture of both actual foreign taxes paid or presumed foreign tax

Tax Sparing Provision
This is a relief which enables companies to claim foreign tax credits on income which has been exempted or taxed at a lower rate in the foreign country. The rationale behind this relief is to promote industrial, commercial, scientific, educational or other development in the foreign country.