A Protected Cell Company (PCC) is a specialised corporate structure that allows businesses to operate multiple independent divisions, known as cells, within a single legal entity. This structure offers a unique advantage by segregating assets and liabilities between different cells, ensuring that financial risks remain contained within each respective compartment. The PCC model is widely used in investment funds, insurance, structured finance, and corporate structuring, due to its flexibility and efficiency.
Each cell within a PCC functions independently in terms of financial operations, asset ownership, and liability management. However, all cells operate under the governance of a single board of directors overseeing compliance and regulatory adherence. This arrangement allows businesses to manage multiple investment portfolios or business lines under one umbrella while maintaining clear legal and financial separation.
A key feature of PCCs is the ring-fencing of assets and liabilities. The financial obligations of one cell do not impact another, providing a high level of investor and creditor protection. This ensures that companies can run diversified investment strategies, structured finance operations, or risk management services within separate cells without exposing the entire business to undue risks.
Additionally, PCCs offer cost-efficient management and scalability. Instead of creating multiple standalone entities, businesses can expand their operations simply by adding new cells, avoiding the time and expense of forming entirely new legal structures. Each cell can also be closed or transferred without disrupting the overall PCC, making it a highly adaptable corporate structure for companies seeking long-term flexibility.
Mauritius is one of the few jurisdictions that have adopted comprehensive PCC legislation, making it an ideal location for businesses looking to take advantage of this model. The country’s robust financial ecosystem, investor-friendly regulations, and tax-efficient environment, make it a preferred jurisdiction for establishing PCCs.
Mauritius As A Jurisdiction For PCCs
Mauritius has gained international recognition as a leading financial hub, offering a stable, transparent, and business-friendly environment for global investors. As a jurisdiction of choice for Protected Cell Companies, Mauritius provides regulatory certainty, tax advantages, and ease of doing business.
The Financial Services Commission (FSC), the regulatory authority overseeing PCCs, ensures that these structures operate in full compliance with international standards. Investors benefit from legal protection, financial stability and a strong regulatory framework, making Mauritius one of the most secure jurisdictions for structuring investments.
Mauritius' favourable tax regime is another key advantage. Companies structured as Global Business Licence (GBL) entities within a PCC framework enjoy a corporate tax rate of only three per cent on foreign-sourced income, making it a highly tax-efficient option. The country’s extensive Double Taxation Agreements (DTAs) and Investment Promotion and Protection Agreements (IPPAs) provide additional security, allowing businesses to minimise tax liabilities and protect investments across multiple jurisdictions.
Another key factor that makes Mauritius attractive for PCCs is its geographic positioning between Africa and Asia. This strategic location enables companies to access high-growth markets with ease, making Mauritius the ideal jurisdiction for businesses looking to expand into emerging economies.
Key Takeaways
A Protected Cell Company (PCC) is an efficient corporate structure that allows businesses to manage multiple investment strategies within legally segregated cells.
Mauritius offers a robust regulatory framework, tax benefits and access to DTAs and IPPAs, making it an attractive jurisdiction for establishing PCCs.
For businesses and investors looking to optimise their investment structures, PCCs offer a flexible and secure solution within Mauritius' internationally recognised financial sector.
Dr Ludovic C. Verbist
PhD, LLM, TEP, Managing Director of AAMIL (Mauritius) Ltd. Ludovic has contributed to a number of articles and interviews, including: Prudence et Préservation du Capital - Business Magazine (October 2017); Guaranteed Real Estate Investment – Cap Sur Maurice Magazine (October 2018); Luxury Property Market in Mauritius – Cap Sur Maurice Magazine (October 2019); Vendre Maurice comme une destination refuge – Le Mauricien Newspaper (May 2020); Jouer à fond la carte africaine dans l’ère post-Covid-19 – Business Magazine (May 2020); Global Business « Désamorcer la Bombe » - Business Magazine (June 2020); Liste Noire – La bataille se jouera sur le terrain diplomatique - Business Magazine (July 2020); Interview – « Parlons économie » - Radio Lac (October 2020); «Maurice face à la menace d’un maintien prolongé sur la liste noire » - Business Magazine (February 2021).