Protected Cell Company (PCC)

A Protected Cell Company (PCC) is a single legal entity that creates distinct “cells” within its structure, allowing for the legal segregation of assets and liabilities between those cells. It is governed by the PCC Act 1999 and must be licensed as a Global Business Company.

Each cell has its own portfolio of assets (cellular assets) and liabilities, which are legally separate from the core assets and from other cells. This makes the PCC structure highly effective for managing multiple investment strategies, insurance risks, or asset classes under one entity.

Key Features

One legal entity with unlimited separate cells
No minimum capital requirement (except for insurance businesses)
Assets and liabilities are ring-fenced per cell
May issue cellular dividends per cell
May be incorporated directly or converted from an existing company
Directors must clearly identify each cell in all transactions
Strong creditor protection framework under the PCC Act

Typical Uses

Collective Investment Schemes (CIS) with multiple share classes or sub-funds
Insurance and reinsurance structures, including life, non-life, and captive insurance
Rent-a-captive solutions for third parties needing risk coverage without owning a captive
Multinational groups consolidating functions (treasury, insurance, investments) under one platform
Geographically or operationally distinct investment strategies segregated in different cells

Incorporation & FSC Licensing

A PCC may be incorporated directly or through continuation (re-domiciliation). All applications must be submitted to the Financial Services Commission (FSC) via a licensed management company and must include:

Business plan for the PCC and each cell
Policyholder or investor profiles
Corporate statutory documents
Information on promoters, functionaries, and regulatory compliance (where applicable)

New cells created post-licensing must also be disclosed to the FSC with supporting documentation.

Taxation

A PCC is subject to income tax at 15%, with access to Mauritius’ partial exemption regime (reducing the effective tax rate to 3%) or credit for actual foreign taxes paid, including:

Withholding taxes
Underlying taxes on foreign corporate profits
Tax sparing credits under Mauritius legislation

Surplus foreign tax credits may be applied across different income types and source countries. PCCs that are managed and controlled from Mauritius may also benefit from Double Taxation Avoidance Agreements (DTAAs).

There is no withholding tax on dividends, interest, or capital gains in Mauritius.

Key Features of a Protected Cell Company

Features
Name	"Protected Cell Company" or "PCC" to be included after the name of a PCC
Cell Name	Each cell to have its own distinct name
Assets of PCC	- Cellular assets or non-cellular assets or both - Cellular assets of each cell to be kept separate from each other and from non-cellular assets
Liability of PCC	- Limited to a particular cell primarily - If assets of the particular cell are insufficient, the PCC's non-cellular assets are secondarily liable but never the cellular assets of another cell
Taxation
Capital
Corporate Tax	15% - can avail to partial exemption of 80% depending on activity
Tax Return	Yes - quarterly and annual
Capital Gains Tax	No
Bank Account	To maintain principal bank account in Mauritius at all times
Directors	At least 2 resident directors
Shareholders	Minimum 1
Company Secretary	Qualified and resident in Mauritius
Registered Office	Shall be in Mauritius