Register a Company in India from Mauritius

Author: Manu Rao | Updated: March 2026

At a Glance

The Mauritius-India Investment Corridor

No country has sent more cumulative FDI to India than Mauritius. The numbers are staggering: USD 180 billion in equity inflows from April 2000 to March 2025, representing 25% of all foreign direct investment India has ever received. In FY 2024-25 alone, Mauritius contributed USD 8.34 billion — 17% of total FDI — making it the second largest source after Singapore.

The relationship goes far beyond money. About 894,848 people of Indian origin live in Mauritius. That is 66% of the entire population — the highest proportion of any country on earth. Between 1834 and 1920, nearly 700,000 Indian indentured laborers arrived on the island. Their descendants now form the backbone of Mauritian society and its financial services industry.

Bilateral trade reached USD 887.25 million in FY 2024-25. India exported USD 676.34 million to Mauritius and imported USD 210.91 million. That trade has grown 329% over 17 years — from USD 206.76 million in FY 2005-06. India is the largest trading partner of Mauritius.

The India-Mauritius CECPA (a broad economic cooperation and partnership agreement), active since 1 April 2021, was India's first trade agreement with an African country. It provides duty-free access for 376 products, reduced duties on 127 more, and tariff rate quotas on 112 products. Utilization is growing fast — from USD 1.1 million in 2021 to USD 4 million in 2024.

In September 2025, both countries signed USD 680 million in cooperation projects covering infrastructure, capacity building, and economic development.

How 2017 Changed Everything for Mauritius-Routed Investments

For decades, Mauritius was the default route for foreign money entering India. The original 1982 DTAA provided full capital gains exemption on sale of Indian shares through Mauritius entities. Fund managers, PE firms, and holding companies worldwide funneled investments through Port Louis to avoid Indian capital gains tax.

That ended on 1 April 2017.

The 2016 Protocol to the DTAA removed the capital gains exemption. Shares acquired after 1 April 2017 are now fully taxable in India. No phase-in, no reduced rates — full domestic tax applies.

Shares acquired before 1 April 2017 are grandfathered. The exemption still applies to those holdings. But the pool of grandfathered investments shrinks every year as pre-2017 positions are exited.

Then India's GAAR (General Anti-Avoidance Rules) kicked in simultaneously. Tax authorities gained the power to deny treaty benefits to arrangements whose primary purpose is tax avoidance. For Mauritius structures, this was a direct hit.

And it is not over. In March 2024, India and Mauritius signed another Protocol introducing the Principal Purpose Test (PPT). Once ratified, this will deny treaty benefits if obtaining a tax advantage was even one of the principal purposes of the arrangement. The PPT is broader than the LOB clause — it applies to ALL treaty benefits, not just capital gains. A CBDT Circular from January 2025 clarified that pre-April 2017 shares will not be subject to the PPT, protecting grandfathered investments.

Why Mauritius Still Works — If You Do It Right

Despite the treaty changes, Mauritius contributed USD 8.34 billion in FDI to India in FY 2024-25. That is not a country investors have abandoned. Here is why it still works.

First, the DTAA withholding rates remain favorable. Dividends are taxed at just 5% if the beneficial owner holds 10% or more of the paying company's capital. Interest at 7.5%. These are among the lowest rates in India's treaty network.

Second, Mauritius has 46 DTAAs with countries across Africa, Asia, and Europe. It is a genuine international financial center — not a one-trick treaty shopping destination. The Economic Development Board actively promotes Mauritius as a gateway for India-Africa investment flows.

Third, the operating environment is favorable. Zero capital gains tax in Mauritius. No exchange controls. Full capital account convertibility. English and French are both widely spoken. The time zone (UTC+4) aligns well with India (UTC+5:30) — only 90 minutes apart.

Fourth, the Global Business Corporation (GBC) structure offers a 3% effective tax rate. Since January 2019, GBCs are taxed at the standard 15% corporate rate but can claim an 80% Partial Exemption Regime (PER) on qualifying income. That brings the effective rate down to 3%.

GBC Substance Requirements You Cannot Ignore

The Financial Services Commission (FSC) — Mauritius's sole licensing authority for GBCs — tightened substance requirements sharply after 2019. If you are setting up a Mauritius GBC to invest in India, here is what the FSC now requires.

Your GBC must carry out Core Income Generating Activities (CIGA) in or from Mauritius. It must incur minimum expenditure in the country and employ adequate qualified persons locally.

Specifically: maintain your principal bank account in Mauritius. Hold board meetings with at least two Mauritius-resident directors. Keep accounting records at your registered office in Mauritius. Have financial statements audited in Mauritius by a local firm. Outsourcing of CIGA is permitted, but the outsourced activities must be conducted from within Mauritius.

Getting the GBC licence itself takes 4-8 weeks through the FSC. Annual compliance and renewal requirements are substantial. Between resident directors, local employees, office space, and auditors, the ongoing operational commitment is real.

The Gift City Question

NRIs and fund managers are increasingly looking at India's GIFT City International Financial Services Centre (IFSC) in Gujarat as an alternative to Mauritius. The shift accelerated in 2025-26, driven by two factors: better IFSC-regulated investment products and mounting compliance costs for offshore structures.

GIFT City offers tax holidays, simplified regulations, and the advantage of being onshore in India. For wealth structuring and fund management, it is a serious competitor to Mauritius.

That said, Mauritius still offers something GIFT City cannot — a base for Africa-bound investments, a 46-DTAA treaty network, and decades of institutional knowledge in cross-border financial services. The two are not substitutes. They serve different purposes.

Choose Your Entity Type

Mauritius investors entering India have four options.

Private Limited Company — the standard choice for GBCs investing into Indian operating businesses. Two directors minimum, one must be an Indian resident (120+ days in the previous calendar year). Full limited liability. Annual statutory audit is mandatory. This structure works best when you plan to have real operations, hire employees, or raise additional capital in India.

Limited Liability Partnership (LLP) — lighter on compliance. No mandatory board meetings. No audit below certain revenue and contribution thresholds. The resident partner must have spent 120 days in India — competitors often incorrectly state 182 days, confusing tax residency with LLP eligibility under the LLP Act, 2008. FDI is allowed only under the automatic route in 100% FDI sectors.

Branch Office — operates under RBI approval via FEMA regulations. Can conduct the parent company's business activities in India. Profits are taxable in India. Suitable for Mauritius entities that want Indian market presence without a separate legal entity.

Liaison Office — the most restricted option. Cannot generate revenue in India. Limited to market research, promotion, and communication. RBI grants permission for 3 years, renewable.

FDI Route and Sector Rules

Mauritius is not a bordering country. Press Note 3 (2020) does not apply.

Automatic route sectors (no government approval needed) include IT, manufacturing, e-commerce (marketplace model), food processing, renewable energy, healthcare, hospitality, and single-brand retail up to 100%.

Government approval is required for defence beyond 74%, print media, multi-brand retail, and broadcasting.

Prohibited sectors: atomic energy, lottery, gambling, chit funds, Nidhi companies, tobacco manufacturing, and real estate business (with construction-development exceptions).

The pattern from Mauritius is distinct. Financial services and fund management dominate, followed by IT services, trading, telecommunications, and construction. This reflects the GBC-driven nature of Mauritius investment — most capital flows through structured financial vehicles rather than direct operating companies.

Step-by-Step Registration Process

Document Checklist for Mauritius Investors

For each director and shareholder based in Mauritius:

• Passport (color scan, all pages)
• Address proof — utility bill or bank statement (not older than 2 months)
• Passport-size photograph
• Board resolution from Mauritius GBC authorizing India investment (apostilled)
• GBC licence from the Financial Services Commission
• Certificate of Incorporation of the Mauritius entity (apostilled)
• Constitution/Articles of the Mauritius entity (apostilled)
• Bank statement showing source of investment funds
• Tax Residency Certificate from the Mauritius Revenue Authority (for DTAA claims)

Apostille is handled by the Prime Minister's Office (Home Affairs Division), 7th Floor, Government Centre, Port-Louis. Mauritius has been a Hague Convention member since 1965. Timeline: 2-5 business days. Documents in English or French are accepted without translation.

Common mistakes: submitting the GBC licence without apostille, providing address proof older than 2 months, and failing to include the full beneficial ownership chain for GBC structures.

DTAA Tax Rates: India-Mauritius

Current withholding tax rates under the India-Mauritius DTAA (post-2016 Protocol):

The 5% dividend rate for 10%+ ownership is one of the lowest in India's entire treaty network. Surcharge and cess do not apply over treaty rates. Claiming these rates requires a Tax Residency Certificate (TRC) from the Mauritius Revenue Authority, plus proof of substance and commercial purpose.

Capital gains: fully taxable in India for shares acquired after 1 April 2017. Pre-2017 acquisitions remain exempt (grandfathered). The PPT, once ratified, will add another layer of scrutiny — but CBDT has confirmed it will not touch pre-2017 holdings.

Realistic Timeline

Total: 6-8 weeks. Here is what that actually looks like.

• DSC + DIN: 1-3 days
• Name reservation: 1-4 days
• Document preparation + apostille in Mauritius: 1-2 weeks
• SPICe+ filing to Certificate of Incorporation: 5-15 working days
• Bank account opening: 2-4 weeks (foreign-owned entities face enhanced KYC)
• GST registration: 1-3 weeks

The Mauritius-India time zone difference is only 90 minutes, which makes coordination smoother than most jurisdictions. Document apostille in Mauritius is also faster than many countries — 2-5 business days at the PM's Office.

If you are also setting up a GBC in Mauritius as the holding entity, add 4-8 weeks for FSC licensing before the India incorporation process begins.

Post-Registration Compliance

Your compliance obligations start from day one.

• FC-GPR filing with RBI — within 30 days of allotting shares to the Mauritius investor. This is a FEMA requirement. Non-compliance triggers penalties and potential enforcement action.
• Board meetings — 4 per year (Private Limited). First meeting within 30 days of incorporation.
• Annual General Meeting — by September 30 each year.
• AOC-4 — financial statements to MCA within 30 days of AGM.
• MGT-7 — annual return within 60 days of AGM.
• Statutory audit — mandatory annually regardless of size.
• Income tax return — by October 31 for companies requiring transfer pricing audit.
• GST returns — monthly or quarterly if registered.
• Transfer pricing — documentation required for all related-party transactions with the Mauritius parent. Indian authorities are particularly alert to Mauritius-linked transfer pricing given the route's history.

Bank Account Opening

Budget 2-4 weeks. Foreign-owned companies go through enhanced KYC checks.

You will need FATCA/CRS declarations, verification through an Authorized Dealer bank, and documentation showing the source of initial capital inflow. Given the historical scrutiny of the Mauritius route, banks may ask additional questions about the GBC structure, its licensing status, and the ultimate beneficial owner.

Foreigner-friendly banks include HDFC Bank, ICICI Bank, and Yes Bank, which have dedicated teams for foreign-invested companies. Start the process immediately after receiving the Certificate of Incorporation.

Profit Repatriation

Getting profits back to Mauritius requires careful tax compliance.

Dividends — most common method. Only 5% TDS if the Mauritius entity holds 10%+ of the Indian company's capital. Since DDT was abolished in April 2020, the shareholder pays directly. Process: declare dividend, deduct TDS, issue Form 16A, obtain CA certificate (Form 15CB), file Form 15CA online, and instruct the AD bank to remit.

Royalties and management fees — 15% WHT on royalties, 10% on FTS under the DTAA. Must be backed by legitimate intercompany agreements at arm's length pricing.

Share buyback — taxed as additional income of the company. Can serve as an exit mechanism.

Mauritius has no exchange controls and no tax on incoming dividends or capital gains. The effective tax on repatriated profits is limited to Indian withholding, provided the structure is properly documented and the GBC meets substance requirements.

Exit Strategy

Planning your exit before you start is not pessimism — it is good practice.

Strike-off (Section 248, Companies Act 2013) — for dormant companies with nil assets and liabilities. File form STK-2 with MCA. Timeline: 3-6 months. All tax liabilities must be cleared and bank accounts closed.

Voluntary liquidation (Insolvency and Bankruptcy Code, 2016) — for companies with active operations. Requires special resolution, appointment of liquidator, and completion within 12 months (extendable). More thorough but provides a clean closure.

If your Mauritius GBC is also being wound down, coordinate the Indian and Mauritian closures carefully. FSC requires its own deregistration process.

How Beacon Filing Helps

We handle the complete India entry process for investors based in Mauritius. From initial structuring through post-incorporation compliance, here is what we cover:

• Foreign Direct Investment advisory — route selection, sector analysis, RBI compliance, and FC-GPR filing
• Resident Director services — appointment of a qualified Indian resident director who meets the 120-day requirement
• Company setup and incorporation — SPICe+ filing, DSC, DIN, name reservation, and Certificate of Incorporation
• Tax and DTAA advisory — treaty benefit structuring, transfer pricing documentation, and annual compliance
• Accounting and statutory audit — bookkeeping, financial statements, ROC filings, and GST returns

Related Country Guides

Setting up from a different country? These guides cover similar territory:

• Register a Company in India from United Arab Emirates
• Register a Company in India from Singapore
• Register a Company in India from South Africa

Get in Touch

Setting up an Indian company from Mauritius? Talk to us. No commitment, no generic sales pitch. We will walk you through the structure, timeline, and costs specific to your situation.

WhatsApp: +91 874 501 3644 | Email: hello@beaconfiling.com