Aviation in Africa is often more of a necessity than purely for pleasure, but is growing strongly. The difficulty in moving around Africa without transiting through a European hub has meant that more and more corporates and HNW individuals have purchased their own aircraft. Of interest then is the choice of where to own the aircraft, where to register it and where to finance it. Aviation in Mauritius has become more and more relevant not least because of the devastating impact of Covid on the islands connectivity, as it is the primary way that the island connects with other countries.
The jurisdiction is not that well known for aircraft registration, however, it has long been a financing choice for large leasing operations particularly into South Africa. In our view, however, it is a natural home for aircraft ownership and financing, particularly if combined with registration on one of the more established registration regimes or in the home country.
Mauritius is keen to expand the aviation sector. This has been borne out by the special treatment accorded to aircraft leasing income. The normal Income Tax rate in Mauritius is 15% but dividends interest and aircraft leasing income is taxed at 3%. This is a clear recognition of the tendency nowadays is for airlines to lease aircraft rather than buy. However, the lack of aviation maintenance facilities means that for now ownership and registration needs to be separated from registration. With an African focus more commercial leasing operations will in any event be obliged to register the aircraft in whichever country it operates. The same does not hold true for private jets which do not need specific regulation in the country of operation.
Mauritius is home to a number of banks with structuring capability and home to banks with aviation specialist departments. The ability to fund aircraft with finance teams who understand aviation is a huge plus and will likely lead to a rapid expansion of this sector.
Given that a private jet has more flexibility with regards to registration we note that it is entirely possible to own and finance a jet in Mauritius but operate it on a domestic African register which makes operation for crew and maintenance quite simple.
However, it is also possible to register the aircraft in a very well known private and corporate jet registration location such as the Isle of Man or the Cayman Islands. We note that Mauritius is specifically mentioned in the list of “Qualifying Countries and Territories” by the Isle of Man civil registry. Similarly as Mauritius is part of the Commonwealth a Mauritius entity is entitled to register an aircraft in the Cayman Islands.
Once so registered there is a fast track system of validation of flying licences and maintenance facilities.
benefits of the arrangement
Structuring ownership and registration in this manner allows for any manner of benefits which include:
Owning an aircraft in a very financially location with a beneficial rate of tax of 3%;
Access to numerous Double Tax treaties including a multitude into Africa;
Access to a banking system geared to aviation financing;
Allowing registration either domestically or in the Isle of Man or Cayman Islands with all the sophistication and flexibility offered by those jurisdictions.
If you require any further information or assistance please speak to Peter Todd in our office in Mauritius, or email email@example.com