Popular investment vehicles in Mauritius

Updated on December 2023

• Variable Capital Companies (VCC)
• Collective Investment Scheme (CIS)
• Closed-End Fund (CEF)

• Company

(i) Company;

(ii) Trust;

(iii) Limited Partnership; or

(iv) Foundation

(i) Company;

(ii) Trust;

(iii) Limited Partnership; or

(iv) Foundation

• VCCs, sub funds and SPVs set up under the Variable Capital Companies Act 2022 are treated similarly to companies under the Income Tax Act 1995 and are generally taxed at 15%. 
• VCCs may be entitled to partial exemptions of 80% on certain types of income (subject to meeting substance requirements). They may alternatively apply for certain tax credits on foreign-sourced income. 
• If a VCC presents separate financial statements for each of its sub-funds or SPVs, then each sub-fund or SPV is liable to income tax individually. 
• Where the VCC presents consolidated financial statements, the VCC fund will be liable for income tax on the aggregate income of its sub-funds and SPVs. 
• Tax-resident VCCs also have access to double tax treaties of Mauritius.

• Liable to income tax on its chargeable income at the rate of 15%. 
• CIS may however benefit from an exemption of (i) 80% on their income (other than interest income); and (ii) a 95% exemption on their interest income, subject to the satisfaction of the relevant substance requirements, subject to the satisfaction of the relevant substance requirements.

• Liable to income tax on its chargeable income at the rate of 15%
• CEFs may benefit from partial exemptions of (i) 80% on their income (other than interest income), and (ii) 95% on their interest income, subject to the satisfaction of the relevant substance requirements.

• If the transfer of shares in a company or issue of new shares by a company gives rise to a right of ownership, occupation or usage in an immovable property in Mauritius, registration duty and land transfer tax of 5% on the value of the immovable property are payable to the Registrar General. Should there be no immovable property involved as set out above there are no transfer taxes. 
• Where the company holds a global business license and does not reckon any immovable property as asset, the transfer shall be exempted from any registration.

• If the transfer of shares in a CIS or issue of new shares by a CIS gives rise to a right of ownership, occupation or usage in an immovable property, located in Mauritius, a duty of 5% on the value of the immovable property is payable to the Registrar General 
• Should there be no immovable property involved as set out above there are no transfer taxes. 
• Where the CIS holds a global business license and does not reckon any immovable property as asset, the transfer shall be exempted from any registration.

• If the transfer of shares in a CEF or issue of new shares by a CEF gives rise to a right of ownership, occupation or usage in an immovable property a duty of 5% on the value of the immovable property is payable to the registrar general (the property has to be situated in Mauritius)

• Yes

• Yes

• Yes

• Open and closed-ended

• Open- ended 

• Closed- ended 

• The Registrar of Companies of Mauritius, the Financial Services Commission of Mauritius and the Mauritius Revenue Authority

• The Registrar of Companies of Mauritius, the Financial Services Commission of Mauritius and the Mauritius Revenue Authority

• The Registrar of Companies of Mauritius, the Financial Services Commission of Mauritius and the Mauritius Revenue Authority

• None

• This will depend on whether the CIS is a retail scheme, a professional CIS, an expert CIS or a specialised CIS.

• None

• No restriction on the number of sub-funds and SPVs that can be created under the VCC structure.
• Each sub-fund may opt to have a legal personality distinct from the VCC. 
• Each sub fund or SPV incurs liability on its own and are segregated ensuring ring-fencing of the assets and liabilities of each sub fund in case of insolvency.
• Cross sub-fund investments and cross SPV investments are permitted within the same VCC.

• Suitable for a large number of investors. 
• Flexible structure. 
• Can apply for authorisation to the Financial Services Commission of Mauritius to act as an expert fund, a specialised collective investment scheme or professional collective investment scheme.

• No requirement to conduct daily valuations. 
• No such requirement as to minimum funding. 
• No need to appoint a custodian.

• As a relatively new vehicle, the market is only starting to discover the vehicle although there are already several VCCs which have been incorporated.

• Regulated framework and statutory requirements (this is also a positive aspect depending on the investors targeted).

• Compared to a CIS, the holder of securities in a CEF cannot redeem them at their net assets value.
• Participants in a CEF do not have day to day control over the management of the property.

• All strategies 

• All strategies 

• All strategies