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Critique My Lean US - Mauritius Structure (2.1% Effective Tax Rate)

I suggest you to get a consultancy on transfer pricing and international taxation by a lawyer.
really good idea. Much said here in the posts is something you can take with you to better understand your situation which at this point is at big risk.
 
If you can't find a proper solution from everything posted here, I would just set up a regular company in Mauritius and pay the maximum 15% corporate tax and up to 20% personal income tax.

If you want to live there peacefully with your wife, this is probably the best path to take.
 
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can someone explain this to me
"Nonresidents are taxed only on Mauritius-source income"

what does this mean? for example, a company that is not resident in Mauritius, and not registered in Mauritius, sells services to companies in Mauritius.
Is that income Mauritius sourced?

Can someone give me an example that would qualify for tax in the above mentioned example?
 
can someone explain this to me
"Nonresidents are taxed only on Mauritius-source income"

what does this mean? for example, a company that is not resident in Mauritius, and not registered in Mauritius, sells services to companies in Mauritius.
Is that income Mauritius sourced?

Can someone give me an example that would qualify for tax in the above mentioned example?
Examples of Mauritius-source income :
  • Income from employment in Mauritius
  • Profits from businesses operating in Mauritius
  • Rental income from property located in Mauritius
  • Interest earned from Mauritian banks or financial institutions
  • Dividends from Mauritian companies
for example, a company that is not resident in Mauritius, and not registered in Mauritius, sells services to companies in Mauritius.
Is that income Mauritius sourced?
Regarding your question :
Normally, income from services is considered to be sourced where the services are performed, not where the customer is located.
Anything which generates permanent establishment is to be considered Mauritius-sourced income (e.g., long construction works in Mauritius).
Examples :
  • Digital consultation from USA Company (not Mauritius-sourced income)
  • Operating a factory in Mauritius (Mauritius-sourced income)
  • Remote software development for Mauritian clients (not Mauritius-sourced income)
  • Renting out property located in Mauritius (Mauritius-sourced income)
For definitions of PE (Permanent establishment) you can check DTA's (https://www.mra.mu/index.php/taxes-...tZW50IiwicGVybWFuZW50IGVzdGFibGlzaG1lbnQiXQ==)
General one for Mauritius:
  • Branch, office, factory, workshop, or installation used for extraction of natural resources.
  • Building site, construction, installation, assembly, or supervisory services where the activity on the site lasts for a minimum of six months or 12 months, depending on the tax treaty.
And PE rules may differ between DTAs and type of business.
 
You could also just do some better research or find a tax consultancy on Mauritius or some of the many service providers that sell company formation in Mauritius that know the tax rules.

Still as suggested a few times already, register a local company and handle all your business there if you want to live in piece on the island.
 
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Can you make the GBC company as your holdco which owns your US company? I believe dividends received from local resident company is tax free, i have been looking into mauritius myself, its a great option for someone who wants to leave dubai and pay less than 9% and enjoy better quality of life and better air quality.

Can you make the GBC company as your holdco which owns your US company? I believe dividends received from local resident company is tax free, i have been looking into mauritius myself, its a great option for someone who wants to leave dubai and pay less than 9% and enjoy better quality of life and better air quality.
I am sure with some proper structuring you can end up paying around 3-5% which is a win win in comparison to dubai considering the cost of living and lower tax in mauritius plus the geo location makes it a very attractive choise
 
Ok, I think we have the very best option. We create a Kyrgyzstan's high technology park company which recieves all royalties without WHT. This company then distributes all profits without WHT and without tax to the UAE holding, where it is equally tax-free under the participation exemption. You can then live a peaceful live ever after where ever you want, while we rack the dollars for you in pieces and in peace. You can finally rest and laze on the beach.

How does this sound?
 
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