Protected Cell Companies (PCC)

A single legal entity that operates segregated accounts, or cells, each of which is legally protected from the liabilities of the company's other accounts.


An individual client's account is insulated from the gains and losses of other accounts, such that the PCC sponsor and each client are protected against liquidation activities by creditors in the event of insolvency of another client.

  • Main features

  • Different cells are taxed separately.
  • Favourable tax treatment under the double taxation avoidance agreements whilst being taxed as a single entity.
  • Legal segregation and protection of assets and liabilities for each cell.
  • May be incorporated, continued or converted from an existing company.
  • No minimum capital requirement is imposed for the PCC and each cell except for insurance business.
  • Taxed as a GBL1 company, thus benefitting from the corporate tax incentive.
  • Unlimited number of cells may be provided, with each cell having its own name or designation.
  • Useful for any investment entity with various investment portfolios where each has its own investment strategy.
  • Uses

As provided under the PCC act, a PCC can be used to carry out two types of global business namely global insurance business and investment funds (i.e. collective investment schemes).

  • Life assurance companies can legally separate the assets of life, pension and individual policyholders.
  • Composite insurers - where the assets of life insurance business need to be legally separated from those of non-life business.
  • Conglomerates - where several cells are established, each holding a particular insurance exposure of the parent and segregated, for example, in relation to the various geographical locations, corporate division or types of risk of those exposures.
  • Insurance and reinsurance - where insurers or reinsurers can accommodate the differing needs of clients.
  • Reinsurance - where finite reinsurance contracts and securitization issues can be placed within separate cells.
  • Multi-nationals - where companies can operate their captive insurance, treasury and other functions globally in a single entity using the same core capital.
  • Captive insurance companies - segregate distinct areas of risk and activity into different cells.
  • Rent-a-captive - where the owners of the PCC offer capital financing to clients, who, because of their own size, would find it impractical to set up their own individual captive insurance arrangements.

This type of structure is particularly attractive for global business funds (collective investment schemes) with various classes of shares, umbrella or multi-class funds, affording each individual share class the same limited liability that would be obtained if separate corporate structures were used for each different category of investor. (Note: it is a requirement that there is pooling of investors' funds at the level of the cell.)

  • Taxation

  • A PCC is liable to Mauritian income tax at the rate of 15% which may be reduced to 0% after application of the provisions on foreign tax credit. For more information consult our Taxation & Tax Treaties page.