Structuring your investments into Africa Ben Lim, CEO, Intercontinental Trust Ltd Mauritius 1

Investment into Africa 2

Investment into Africa – Tax Haven 3

Using a traditional Tax Haven African countries known to have high withholding tax rates No Protection from Double Taxation Agreements No Protection against Nationalisation or Confiscation of Assets 4

Investment into Africa via Mauritius 5

Why use Mauritius for Africa? Mauritius is part of Africa African Union Common Market for Eastern and Southern Africa (“COMESA”) Southern African Development Community (“SADC”) Indian Ocean Rim – Association for Regional Coorperation (“IOR-ARC”) Africa Growth and Opportunities Act (“AGOA”) Excellent Double Taxation Treaties Network Bilateral Investment Treaties Convenient Time Zones / Good Air Connectivity Dual Legal System – English & French

African Investment Funds Mauritius is the favoured jurisdiction for incorporating African Investment Funds African Development Bank (“ADB”) recommends Mauritius as an ideal location for the African Funds Member of the International Organisation of Securities Commissions (“IOSCO”) Over 600 Funds incorporated in Mauritius Modern legislation covering CIS and Fund Managers/Advisers

Mauritius – Recent Awards Index Organisation Africa World Ease of Doing Business World Bank 1st 17th Economic Freedom Heritage Foundation 12th Easiest Country for Trade World Economic Forum 33rd Top Regional Reformer Most Improved Investment Climate African Business Awards Best Governed Country in Africa Harvard University Kennedy School of Governance Ibrahim Index Mo Ibrahim Foundation

** 10 Treaties being negotiated Europe Belgium Cyprus Croatia France Germany Italy Luxembourg Sweden UK Russia* In Negotiation Canada** Czech Republic** Greece** Portugal** Iran** Burkina Faso** Algeria** Yemen** Ghana** Saudi Arabia** Asia Bangladesh China India Malaysia Nepal Pakistan Singapore Sri Lanka Thaïland Vietnam* Middle East Kuwait Oman United Arab Emirates Qatar Africa Botswana Lesotho Madagascar Mozambique Namibia Rwanda Senegal Seychelles South Africa Swaziland Tunisia Uganda Zimbabwe Egypt* Kenya* Malawi* Nigeria* Zambia* Caribbean region Barbados Treaty Network: 36 DTAAs in force * 7 Treaties awaiting signature or ratification ** 10 Treaties being negotiated

DTAs with African Countries Dividends Interest Royalties PE Botswana 5/10% 12% 12.5% 6m Lesotho 10% Madagascar 5% Mozambique 8/10/15% 8% Namibia Rwanda - 12m Senegal 9m Seychelles South Africa 5/15% Swaziland 7.5% Tunisia 2.5% Uganda 4/6m Zimbabwe 10/20% 15%

Africa Europe Asia Investment Promotion and Protection Agreements Belgium Czech Republic France Germany Ireland Luxembourg Portugal Romania Switzerland UK Madagascar Mozambique South Africa Benin* Botswana* Burundi* Cameroon* Chad* Comores* Ghana* Guinea Republic* Mauritania* Rwanda* Senegal* Swaziland* Zimbabwe* Asia Carribean Region China India Korea Nepal Pakistan Singapore Barbados Investment Promotion and Protection Agreements 20 Fully Operational, 13 *Awaiting Ratification

Investment Promotion & Protection Agreement (“IPPA”) Covers every kind of asset Includes concessions to search for, cultivate, extract or exploit natural resources Non-Discrimination Treatment of Investments. Compensation of losses owing to war / other armed conflict Expropriation Right to Compensation Disputes between Investor and Contracting Party Provision for International Arbitration after 6 months Disputes between Contracting Parties Provision for an Arbitral Tribunal Retroactive

Corporate Vehicles Global Business Companies (“GBC”) Activities Category 1 – Tax Treaty Company (“GBC1”) Category 2 – Tax Exempt Company (“GBC2”) Activities Holding Companies Investment Funds Asset Management Companies Private Trusts Trading Companies

Set up a Mauritius Company Incorporation Two weeks Regulated by Financial Services Commission Re-domiciliation (Migration) Most offshore jurisdiction allow companies to migrate out Effective way to continue the company to Mauritius Immediately after re-domiciliation, the company can take advantage of the DTAAs Investment Protection Agreements

Redomiciliation of Companies 15

Countries Allowing Re-domiciliation Andorra BVI Ireland Maldives Seychelles Anguilla Brunei Isle of Man Malta St Kitts & Nevis Antigua Cayman Israel Marshall St Lucia Aruba Cook Jersey Mauritius St Vincent Austria Costa Rica Latvia Montserrat Switzerland Bahamas Cyprus Lebanon Nauru Turks Caicos Bahrain Dominica Liberia Neth. Antilles UAE Dubai Barbados Gibraltar Liechtenstein Panama Uruguay Belgium Grenada Luxembourg Philippines US Virgin Belize Guernsey Macao Madeira USA Delaware Bermuda Hungary Labuan Samoa Vanuatu

Tax Residence A Company is tax resident in Mauritius if it is either: Incorporated in Mauritius; or Managed and controlled from Mauritius Conditions to obtain a Tax Residence Certificate (“TRC”): Two local directors Local company secretary Local auditor Board meetings chaired from Mauritius Statutory records kept in Mauritius Accounting records kept in Mauritius Principal bank account in Mauritius TRC country specific and renewed yearly

Tax in Mauritius No Capital Gains Tax No Profits on Sale of Shares Maximum Corporate Tax of 3% (Most companies pay zero tax) No Withholding Tax on payments from Mauritius Advance Tax Rulings Whitelisted by OECD No Exchange Controls

Intercontinental Trust Ltd Intercontinental Trust has been in existence for over ten years Licensed and Regulated by the Financial Services Commission Principals have been active in this industry for over 15 years Over 100 staff Active participation in the legal and regulatory reform process of the financial services sector in Mauritius Among the leading Trust Companies in Mauritius

Services Incorporation & Administration of Companies Fund Formation and Administration International Tax Planning Trustee Services Accountancy Services Business Process Outsourcing 20

SAS 70 Intercontinental Trust Ltd and its subsidiaries recently obtained their SAS 70 Type II certificate Audit Report Unqualified by PricewaterhouseCoopers One of the first trust companies to have SAS 70 Type II 21

Thank You