Mauritius: Taxation of variable capital companies

A new type of fund structure in Mauritius

A new type of fund structure in Mauritius

A variable capital company (VCC) is a new type of fund structure in Mauritius, introduced by the VCC Act 2022.

A VCC is a company incorporated under the Companies Act and carries its activities through its Sub-Funds (SFs) and Special Purpose Vehicles (SPVs).

If a VCC elects to present consolidated financial statements, the VCC is allowed to file a single tax return and is liable to income tax on the aggregated income of its SFs and SPVs, thereby taking advantage of tax losses in certain SFs or SPVs, which is not possible under generic fund structures. On the other hand, VCCs electing to present separate financial statements for each of its SFs and SPVs will be required to file separate tax returns.

VCCs, SFs and SPVs are eligible to obtain a tax residency certificate upon filing of their tax returns. A VCC is also eligible for tax benefits including the partial exemption regime. As such, its effective tax rate may be considerably reduced.

Read a February 2023 report [PDF 154 KB] prepared by the KPMG member firm in Mauritius


The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.