A Variable Capital Company (“VCC”) is a type structure where activities may be segmented through sub-funds and Special (SPVs). A VCC needs to be authorised by the Financial Services Commission, Mauritius (the “Commission”) as a VCC Fund pursuant to the Variable Capital Companies.

A VCC can be set up as a standalone entity or as an umbrella structure comprising of sub-funds or SPVs.

A VCC Fund can also be set up initially as a standalone fund and further sub-funds can be added subsequently. The sub-fund of a VCC Fund may elect to have separate legal personality from that of the VCC Fund.

The sub-fund or SPV can operate as a Collective Investment Scheme (“CIS”) or a Closed-End Fund (“CEF”) of any category. Kindly refer to our detailed section on Funds and CIS.

A sub-fund or SPV of a VCC fund may be allowed to invest its assets into another sub-fund or SPV of the VCC Fund.

 

Taxation of VCC in Mauritius

Where the VCC fund elects to present separate financial statements, each sub-fund or SPV shall be deemed to be an entity separate from the VCC and shall be liable to income tax in respect of its own income.

Where the VCC presents consolidated financial statements, a single income tax return should be filed with the Mauritius Revenue Authority (MRA) and the VCC would be subject to tax on the aggregated income of its funds and SPVs.

VCC is subject to a Standard tax rate of 15% but can benefit from an 80% partial exemption is available on certain types of income. Foreign tax credit may be claimed on foreign sourced income. Please also note that VCC or any of its sub-funds established under Financial Services Act, the Special Purpose Funds will be tax exempt. No capital gains tax in Mauritius.

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