Client Profile
| Detail | Info |
|---|---|
| Name | Philippe (anonymized) |
| Age | 55 |
| Nationality | French |
| Residence | Mauritius (relocated 3 years ago) |
| Situation | Runs a consulting firm serving French multinationals expanding into Africa |
| Net worth | ~€3M |
| Business | Advisory + co-investment in African real estate and infrastructure projects |
The Problem
Philippe had relocated to Mauritius three years earlier for lifestyle reasons. His wife was Mauritian, and they wanted to raise their children closer to her family. He maintained a French SAS as his consulting vehicle and a personal portfolio in France.
Issues with the existing structure:
| Problem | Impact |
|---|---|
| French SAS taxed at 25% IS | Corporate profits still taxed in France |
| French portfolio taxed at 30% PFU | Non-resident withholding on dividends and gains |
| No African treaty access | French SAS had no treaty benefits for African investments |
| Co-investment structure unclear | Personal investments into African projects — no liability protection |
| IFI exposure | French real estate still subject to IFI (wealth tax on property) |
Philippe wanted to restructure everything through Mauritius — leveraging his residency and the jurisdiction's treaty network.
The Solution
Target Structure
┌─────────────────────────────────────────────┐
│ Philippe (Mauritius resident) │
│ Personal tax: 0-15% (progressive) │
└──────────┬──────────────────┬────────────────┘
│ │
┌──────▼──────────┐ ┌────▼──────────────┐
│ 🇲🇺 Mauritius GBC │ │ 🇲🇺 Mauritius GBC │
│ Consulting Co │ │ Investment Co │
│ (Advisory fees) │ │ (Co-investments) │
└──────┬──────────┘ └────┬──────────────┘
│ │
┌──────▼──────┐ ┌─────▼────────────┐
│ French/EU │ │ African projects │
│ clients │ │ (via DTAs) │
│ (invoicing) │ │ Kenya, SA, Senegal│
└─────────────┘ └──────────────────┘
Phase 1: Mauritius GBC — Consulting Company (Month 1-3)
This replaced the French SAS for all non-French consulting activity.
| Action | Timeline | Cost |
|---|---|---|
| GBC incorporation (consulting license) | 3 weeks | €6,000 |
| FSC license approval | 4 weeks | Included |
| Resident directors (Philippe + local) | Concurrent | €2,000/year |
| MCB corporate account | 2 weeks | €1,000 |
| AfrAsia USD account | 2 weeks | €800 |
Tax on consulting income (Mauritius GBC):
| Element | Rate |
|---|---|
| Corporate tax | 15% |
| Deemed foreign tax credit | 80% of tax (on foreign-sourced income) |
| Effective tax rate | 3% |
Compared to 25% IS in France — an 88% reduction in corporate tax.
Phase 2: Mauritius GBC — Investment Vehicle (Month 2-4)
For Philippe's co-investments in African real estate and infrastructure.
| Action | Timeline | Cost |
|---|---|---|
| Second GBC incorporation (investment holding) | 3 weeks | €6,500 |
| FSC Category 1 Global Business license | 4 weeks | Included |
| Dedicated MCB account | 2 weeks | €1,000 |
| Investment management agreement | 2 weeks | €3,000 (legal) |
Treaty benefits for African investments:
| Investment country | Without Mauritius DTA | With Mauritius DTA |
|---|---|---|
| Kenya (rental income) | 30% WHT | 0-15% WHT |
| South Africa (dividends) | 20% WHT | 5-10% WHT |
| Senegal (capital gains) | 20% | Exempt or reduced |
| Madagascar (dividends) | 20% WHT | 5% WHT |
Phase 3: French SAS Wind-Down (Month 3-6)
Philippe kept the French SAS open but limited to French-sourced clients only (small portion of his business).
| Action | Detail |
|---|---|
| Reroute non-French clients to Mauritius GBC | New contracts signed with Mauritius entity |
| Transfer French portfolio | Some positions maintained in France (PEA), others transferred |
| French real estate | Kept — still subject to French tax rules, but IFI declaration updated |
French SAS retained for:
- 2 French clients who require a French invoicing entity
- PEA (Plan d'Épargne en Actions) — tax-advantaged, cannot be moved
- French property management
Tax Comparison (Annual)
Consulting Revenue (€250K/year)
| Item | French SAS | Mauritius GBC | Savings |
|---|---|---|---|
| Revenue | €250,000 | €250,000 | — |
| Corporate tax | €62,500 (25%) | €7,500 (3%) | €55,000 |
| Social charges on distribution | ~€12,000 | €0 | €12,000 |
| Dividend tax (PFU 30%) | ~€40,000 | 0% (resident) | €40,000 |
| Annual tax savings | €107,000 |
Investment Returns (~€100K/year from African projects)
| Item | Personal (France) | Via Mauritius GBC | Savings |
|---|---|---|---|
| Gross returns | €100,000 | €100,000 | — |
| WHT at source (avg) | 20% = €20,000 | 7% = €7,000 | €13,000 |
| French PFU on remaining | 30% = €24,000 | N/A | €24,000 |
| Mauritius tax (3%) | N/A | €3,000 | — |
| Annual tax savings | €34,000 |
Total Annual Impact
| Category | Savings |
|---|---|
| Consulting restructuring | €107,000 |
| Investment treaty benefits | €34,000 |
| Total annual savings | €141,000 |
| Structure maintenance costs | -€18,000 |
| Net annual benefit | €123,000 |
Banking Setup
| Account | Bank | Currency | Purpose |
|---|---|---|---|
| Consulting GBC | MCB | EUR + USD | Client invoicing |
| Investment GBC | MCB | USD | Investment flows |
| Investment GBC (secondary) | AfrAsia | USD + ZAR | African corridor |
| Personal | AfrAsia | EUR + USD + MUR | Personal wealth |
Why MCB + AfrAsia combination?
- MCB: Strongest correspondent banking network in Mauritius, trusted by European clients
- AfrAsia: Purpose-built for Africa-Asia capital flows, best for investment repatriation
Substance Requirements
Mauritius GBC requires genuine economic substance. Philippe exceeded requirements:
| Requirement | Philippe's setup |
|---|---|
| At least 2 resident directors | ✅ Philippe (resident) + 1 local professional director |
| Registered office in Mauritius | ✅ Licensed management company |
| Board meetings in Mauritius | ✅ All meetings held in Mauritius |
| Local bank accounts | ✅ MCB + AfrAsia |
| Local employees or service providers | ✅ Local accountant + compliance officer |
| Strategic decisions made in Mauritius | ✅ Philippe is based in Mauritius |
Timeline
Month 0 → Engaged Private Office
Month 1-3 → Consulting GBC incorporation + banking
Month 2-4 → Investment GBC incorporation + banking
Month 3-5 → Client contracts migrated to Mauritius entity
Month 4-6 → French SAS scope reduced (French clients only)
Month 6 → First investment made through Mauritius GBC
Month 7 → Fully operational dual-GBC structure
Services Used
| Service | Cost |
|---|---|
| Private Office — Mauritius GBC setup (x2) | Contact us |
| Banking setup (MCB + AfrAsia, 4 accounts) | €3,800 |
| Legal (intercompany agreements, investment docs) | €8,000 |
| French tax advisor (restructuring + SAS wind-down) | €6,000 |
| Total setup | ~€35,000 |
| Annual maintenance | ~€18,000 |
| Payback period | ~4 months |
Key Takeaways
- For French entrepreneurs already in Mauritius, the GBC structure is a natural extension of residency
- The 3% effective tax rate on foreign-sourced income is one of the lowest available in a compliant, regulated jurisdiction
- Mauritius treaty network with Africa is unmatched — critical for anyone investing on the continent
- Dual GBC structure (consulting + investment) cleanly separates active and passive income
- French SAS can be retained for French-only clients rather than fully liquidated
- Substance is real and must be maintained — but if you actually live and work in Mauritius, this is straightforward
⚠️
Disclaimer: Treaty benefits require meeting substance and beneficial ownership tests. GBC licensing is regulated by the Mauritius FSC. Professional advice is required.