Mauritius Global Headquarters (GHQ) licence: Tax holiday, substance rules and business benefits

Mauritius offers an attractive framework for international companies looking to set up their global or regional headquarters: the Global Headquarters (GHQ) licence. StraFin Corporate explains how this licence combines substantial tax advantages with strict economic substance requirements, positioning Mauritius as a strategic jurisdiction for multinational groups seeking to centralise management, coordination and support services.

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What is the GHQ licence?

The Global Headquarters licence is a legal status granted by the Mauritian authorities to companies wishing to establish their global or regional headquarters in the country. The purpose of this regime is to attract strategic decision-making centres capable of providing qualifying services to multiple entities within the same international group.

Unlike purely tax-driven structures, the GHQ licence requires a genuine operational presence in Mauritius, including hiring resident employees, incurring substantial local expenditure and maintaining dedicated office space. Its framework aligns with international economic substance standards while offering a highly competitive tax environment.

Tax benefits of the GHQ licence

Eight-year corporate tax holiday

Companies holding a GHQ licence are eligible for a full exemption from corporate income tax for eight consecutive years. This exemption applies to all profits generated from headquarters activities, allowing multinational groups to significantly reduce their overall tax burden during the deployment and consolidation phases of their operations.

Zero capital gains tax

Mauritius does not levy capital gains tax for GHQ licence holders. This applies to gains from the disposal of assets, equity interests or investments, offering substantial flexibility for group restructuring and external growth transactions.

Access to tax treaty network

Mauritius has an extensive network of double taxation treaties with over 40 jurisdictions, including major global economies. GHQ companies can use these treaties to reduce or eliminate withholding taxes on dividends, interest and royalties paid to or from Mauritius, improving the efficiency of intra-group financial flows.

Economic substance requirements

Obtaining and maintaining the GHQ licence requires meeting strict criteria that demonstrate real economic activity in Mauritius. These requirements fall into three main categories.

Employment threshold

The company must employ at least 10 full-time resident professionals based in Mauritius who carry out genuine headquarters functions. Among these 10 employees, at least two must hold senior management positions, ensuring that key decision-making authority is effectively located in Mauritius.

This requirement guarantees that strategic control centres operate locally rather than being artificially located in the jurisdiction for tax optimisation purposes.

Read also: Mauritius Finance Bill 2025 explained: Tax, residency permits, and investment rules

Minimum annual operating expenditure

A GHQ company must incur at least Rs 5 million in annual operating expenses in Mauritius, which is roughly USD 150,000. These expenses include salaries, rent, professional services and other costs required to operate the headquarters.

This financial threshold demonstrates real investment in the local economy and prevents the creation of structures with little or no activity.

Physical office and banking presence

Two additional obligations reinforce the economic substance requirement. The company must maintain and operate a dedicated physical office space in Mauritius. This means that virtual offices or simple registered addresses are not sufficient.

Furthermore, the GHQ company’s main bank account must be opened and managed in Mauritius. This ensures that essential financial transactions genuinely pass through the Mauritian banking system, strengthening the company’s local economic footprint.

Service mandate: The “3-for-3” rule

Obligation to provide qualifying services

A company holding a GHQ licence must deliver at least three qualifying services to at least three related entities within its international group. This fundamental rule confirms the company’s function as a shared-services hub for the group.

The related entities may be located in any jurisdiction and may take different legal forms, as long as they belong to the same corporate group as the GHQ entity.

List of qualifying services

Mauritian authorities have defined a list of services that may be provided by a GHQ company.

Administration and general management constitute the first type of eligible service, including operational oversight, coordination of subsidiaries, and the implementation of group-wide policies.

Business planning, development, and coordination represent a second area, encompassing the development of commercial strategies, steering development projects, and coordinating activities across different entities within the group.

Research and economic or investment analysis constitute a third category, encompassing market studies, financial analyses, investment opportunity assessments, and strategic decision-making support.

E-commerce administration is also among the qualifying services, reflecting the evolution of business models and the increasing centralisation of digital platforms at the group level.

Finally, services related to international headquarters include all support functions typical of a coordination centre: legal, compliance, human resources, information systems, treasury, and consolidated reporting.

Strategic advantages of the GHQ regime

Structural tax efficiency

The combination of an eight-year tax holiday and access to tax treaties enables multinational groups to structure their financial flows efficiently. Dividends coming from operating subsidiaries and repatriated to the Mauritian headquarters, then redistributed to shareholders, benefit from reduced withholding tax rates, while capital gains remain entirely tax-exempt.

Centralization of support functions

The GHQ framework encourages the pooling of value-added services within a single structure. This centralization generates economies of scale, ensures consistency in group-wide processes and strengthens strategic oversight of international operations.

Compliance with international standards

The economic substance requirements align with OECD and EU criteria on countering base erosion and profit shifting. Mauritius does not appear on any list of non-cooperative jurisdictions, giving companies established under this framework regulatory stability and protection from global policy shifts.

How to apply for a GHQ licence

Obtaining a GHQ licence requires submitting a detailed application to the Economic Development Board (EDB) of Mauritius. The application must demonstrate the company’s ability to meet all substance requirements and provide the required qualifying services.

Authorities review the group’s shareholding structure, the nature of the planned activities, employment and local expenditure projections, as well as the roll-out plan for intra-group services. The processing time typically ranges from a few weeks to several months, depending on the complexity of the file.

Once the licence is granted, the company must remain compliant with all substance requirements throughout the tax holiday period. Authorities conduct regular checks to ensure ongoing compliance with obligations related to employment, expenditure and service provision.

About StraFin Corporate

StraFin Corporate Ltd is an international provider of corporate, trust and fund administration services, established in Mauritius for more than 10 years. The firm assists companies in structuring their operations and obtaining GHQ licences, drawing on its deep expertise in the Mauritian regulatory landscape.

StraFin Corporate provides company formation and administration, governance and corporate secretarial services, tax and regulatory compliance, as well as accounting and financial record keeping. Its team includes licensed company secretaries, chartered accountants and certified corporate administrators who can support every stage of your GHQ project, from preparing the application to managing ongoing substance obligations.

With offices in Ébène, Moka, Grand Bay and Dubai Silicon Oasis, StraFin Corporate relies on a network of legal and financial partners to ensure rigorous, fully compliant support.

To secure your Global Headquarters project in Mauritius and benefit from expert, tailored guidance, contact us directly.