Corporate Structure

Transformative Technologies PCC is a Mauritius based Global Business Company in the legal form of a Protected Cell Company (PCC).

Our business requires the facilitation of product line and/or geographic segmentation. Instead of setting up a group structure of various companies for specific technologies and/or countries which is expensive and unwieldy, we use the PCC as our one and only head company.

Features of a PCC

A PCC is a single legal entity within which may be established various cells. The assets and liabilities of each cell are legally separate from those of the other cells. However, the cells are not independent legal entities separate from the PCC.

A PCC operates in two distinct parts: the Core and the Cells. There is (and must only be) one Core, but there may be an infinite number of Cells. Cellular shares are issued, as required, under different names so as to identify and represent the particular Cells to which they are attributable.

Range of Applications

The PCC legislation represents a major opportunity for many international businesses. Prospective uses include “master-feeder” (umbrella or other mutual fund) structures providing for multiple classes of shares and multiple investment options, property development companies, asset holding or divisions of any company

Where it is advisable or necessary, the Cells can found subsidiaries in the countries where the respective technology shall be introduced. Through the PCC we have access to the benefits of Double Taxation Agreements (DTA) and Investment Promotion and Protection Agreements (IPPA) that Mauritius has signed with many African member states.

Taxation of a PCC

As a Global Business Category 1 Company, a PCC is liable to income tax at the rate of 15% which may be reduced to 3% after application of the provisions on foreign tax credit. No capital gains tax, withholding taxes on interest and dividends shall be payable by the PCC.

Asset Protection

Where assets have been allocated to a particular cell, those assets are held exclusively for the benefit of the owners of the particular cell and any counterparty to a transaction linked to this cell. Only persons who have entered into transactions with the cell, or who otherwise have become creditors of the cell concerned, will have recourse to that cell’s assets. Any asset which attaches to a particular cell is not available to meet liabilities of the PCC or any of the other cells.