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 Societé. A foreign
company including the Global Business Company may benefit from the tax
It is also possible for 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.