Variable Capital Companies – a flexible evolution in fund structuring.
Flexible fund structures have been around for decades, with the UK’s OEIC and Luxembourg’s SICAV being popular examples of flexibility and cost efficiency. These structures have made these jurisdictions the domicile of choice for thousands of funds over this period. To remain competitive in the market and attractive to global investors, Mauritius introduced its Variable Capital Company (“VCC”) framework in 2022 which offer greater flexibility and efficiency in capital management.
How BTG can assist
- Advice on structuring
- Formation of the company
- Provision of Registered Office
- Provision of two Resident Directors
- Provision of a qualified Company Secretary
- Back-office administration and accounting services
- Assistance with opening and administration of local bank account
- Regulatory compliance
- Assist with application for Occupation
Permit
Key Features
What is a Variable Capital Company (VCC)?
A VCC is a flexible and efficient legal structure that allows fund managers to conduct investment activities in a regulated environment, offering multiple benefits like sub-fund creation, shared services, and tax efficiency.
Can a VCC have multiple investment strategies under one structure?
Yes. VCCs allow the creation of multiple sub-funds and special purpose vehicles (SPVs) within a single legal entity. Each sub-fund or SPV can operate independently with segregated assets and liabilities, making it ideal for managing various investment strategies.
How do VCCs help reduce operational costs?
VCCs can share common service providers—such as custodians, brokers, compliance officers, and directors—across all sub-funds and SPVs. This shared model leads to significant cost savings and operational efficiencies.
What are the tax benefits of setting up a VCC in Mauritius?
VCCs in Mauritius are tax residents and subject to a 15% corporate tax rate. However, they enjoy partial exemptions on certain types of income, and benefit from Double Taxation Avoidance Agreements (DTAAs). Additionally, there are no taxes on dividends, withholding tax, or capital gains tax from investments.
Are assets and liabilities protected between sub-funds?
Yes. One of the main advantages of VCCs is the ring-fencing of assets and liabilities. This means the obligations of one sub-fund or SPV do not affect others under the same VCC umbrella.
Main Contact
Pravesh Heeroo
Business Development Specialist
Meet the rest of our Team
Other Services
Authorised Company
An Authorised Company is a company registered in Mauritius whose business activity and control & management are outside of Mauritius.
Discretionary Trust
A Discretionary Trust in Mauritius is a flexible type of Trust mainly used in wealth protection and tax planning. It is established by a settlor who settles assets on trust to achieve the objects of the trust.
Protected Cell Company (PCC)
A PCC is a corporate structure in which a single legal entity is comprised of a core and several cells, and the assets and liabilities of each non-core cell are legally protected from the failure of another non-core cell.
Our Services
Discretionary Trust
A Discretionary Trust in Mauritius is a flexible type of Trust mainly used in wealth protection and tax planning. It is established by a settlor who settles assets on trust to achieve the objects of the trust.
Mauritius Foundation
A Foundation is a legal entity formed for such purposes as may be provided in its charter, including thecarrying out of the objects specified in it.
Global Business License Company (GBL)
A Global Business License Company is a resident corporation which proposes to conduct business principally outside of Mauritius and is licenced by the Financial Services Commission.
Domestic Company
A domestic company is a local company incorporated and governed in Mauritius whose activity can be conducted withresidents of Mauritius as well as with non-residents of Mauritius. However, where the domestic company is controlled by a non-citizen of Mauritius and conducts its business principally outside Mauritius, a Global Business License is required.
Authorised Company
An Authorised Company is a company registered in Mauritius whose business activity and control & management are outside of Mauritius.
Protected Cell Company (PCC)
A PCC is a corporate structure in which a single legal entity is comprised of a core and several non-core cells, and the assets and liabilities of each non-core cell are legally protected from the failure of another non-core cell.









