As part of its commitments to ensure that only companies that are properly controlled and managed in Mauritius are issued a Tax Residency Certificate ("TRC") – which is now a legal pre-condition for a company to avail of the beneficial provisions of the Tax Treaty between India and Mauritius, the Financial Services Commission ("FSC") in Mauritius has made amendments to specify economic substance requirements that Category 1 Global Business Companies ("GBC 1 Companies") will have to comply with. These amendments are summarized in this BMR Alert.