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

2. Investment into Africa2

3. Investment into Africa – Tax Haven3

4. 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

5. Investment into Africa via Mauritius5

6. 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

7. 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

8. 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

9. ** 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

10. 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%

11. 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

12. 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

13. 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

14. 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

15. Redomiciliation of Companies15

16. 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

17. 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

18. 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

19. 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

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

21. 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

22. Thank You