Trusts
A trust is a good legal entity to ring fence and protect assets. It also acts as an inheritance or succession platform. Typically, the Settlor vests property in a trust managed by a trustee (that thus has the legal ownership of the property) for the benefit of a beneficiary (who has the beneficial interest in the property).
Generally, trust properties are shielded from insolvency and bankruptcy risks. A Mauritian trust does not need to be registered, in which case, the trust deed is a private and confidential document and subject to strict confidentiality norms. Trusts will require to file financial summaries to the FSC. Most of the time, trust income constitutes dividends and capital gains that are tax exempt and sometimes interests on loans that will be entitled to partial exemption and thus be taxed at 3% if derived from a foreign establishment. Any other income will be charged at 15%. No statutory licensing or registration fees will be applicable.
Foundations
A foundation is similar to a trust. A founder vests property in a foundation for the purpose of charitable or non-charitable benefits. A foundation is managed by a Council. A foundation is registered at the Registrar. Most of the time, foundation income constitutes dividends and capital gains that are tax exempt and sometimes interests on loans that will be entitled to partial exemption and thus be taxed at 3% if derived from a foreign establishment. Any other income will be charged at 15%.
Family Offices
The Overseas Family Office scheme caters for the domiciliation of assets and wealth of high networth families in Mauritius. The scheme consist of two licenses, one for single family office and the other for multi-family offices.
To be eligible for a license, each family will be required to domicile and actively manage a prescribed minimum investible and liquid wealth base of US$ 5 million. The family office will also be required to maintain, at all times, its physical establishment in Mauritius, as well as other substance requirements.
Under the scheme, family offices will benefit from a tax holiday of 5 years and family members will benefit from residency schemes as well as the eligibility to acquire immovable properties in Mauritius.
The family office takes the form of a private limited company. The statutory fees are as below:
- USD 1,000 as one-off processing fees and USD 2,500 as annual fees payable to the FSC and USD 275 payable annually to the CBRD.
- USD 1,000 as one-off processing fees and USD 2,500 as annual fees payable to the FSC for the first family and USD 500 as one-off processing fees and USD 500 as annual license fees for each additional family payable to the FSC and USD 275 payable annually to the CBRD.
Asset and Fund Managers
The new Fund and Asset Manager Scheme provides mid to big size fund and asset managers with the incentive to establish their management offices especially for their African portfolio in the Mauritius IFC.
The activities of the managers comprise advisory, investment management and asset management services. The incentive will be available to holders of Assets Management License and CIS (Collective Investment Scheme) Manager License.
The Fund and Asset Managers are issued with either an Asset Manager certificate, a Fund Manager certificate, or an Asset and Fund Manager certificate by the FSC.
Such professionals will have to manage assets worth more than US$ 100 million. They will be entitled to a 5 year tax holiday on their emoluments.
Ultra-High Networth Individuals
It is estimated that Africa is home to around 165,000 high net worth individuals(HNWIs) with a combined wealth holding of US$860 billion and this number is set to increase at a rate of 7% as a result of continuous economic development and urbanisation. The Mauritius IFC has developed a scheme to attract ultra-high networth individuals notably from Africa.
- 5 years tax holiday to a non-citizen of Mauritius who makes investment in Mauritius of more than USD 25 million on or after 01 September 2016.
- 5 years tax holiday to companies wholly owned by non-citizens of Mauritius which make investment in Mauritius of more than USD 25 million.