TAX TRAVEL

Five Companies That Went Thousands of Miles to Use Mauritius

Here are five companies that illustrate the vast geographic reach of Mauritius as a tax haven.

Mauritius may be a tiny island 1,200 miles from the African continent, but its reach in the business world stretches far and wide. That much was made clear during our Mauritius Leaks investigation, published in collaboration with 54 journalists in 18 countries.

To unravel how and why companies might include Mauritius as part of their business structures, we spent hundreds of hours combing through details of offshore companies buried in more than 200,000 leaked files from the Mauritius office of the Bermuda-based offshore law firm Conyers Dill & Pearman. We published a spreadsheet to help make this rarely-disclosed information publicly available.

Several cases we found along the way stuck with us. Some showed the vast geographic reach of Mauritius as a tax haven. Others showed the diversity of businesses using the offshore world, ranging from humanitarian aid programs to online travel planning services.

Here are five companies that illustrate this distance and diversity — you can find even more by exploring the data yourself:

1. Golden Agri-Resources Ltd (3,465 miles)

Head office: Singapore
Distance to Mauritius: 3,465 miles
Industry: Palm oil

Golden Agri-Resources Ltd is one of the world’s largest palm oil producers. Listed on the Singapore Stock Exchange but incorporated in Mauritius, it was used between 2013 and 2017 to guarantee at least $2.276 billion in loans to subsidiaries in Indonesia, Hong Kong, and Singapore, and to invest in companies in Liberia and Germany. Golden Agri-Resources Ltd told us that the information was out of date.

Here is the Group Structure Chart behind Golden Agri-Resources’ investment in Golden Veroleum (Liberia) Inc., which was found in the documents.

2. Trident Enterprises Limited (9,174 miles)

Head office: Montreal, Canada
Distance to Mauritius: 9,174 miles
Industry: Airline

Canadian-based DAC Aviation International, which charters humanitarian flights for the United Nations World Food Programme and and the European Commission’s ECHO missions, financed the purchase of two aircraft through Mauritius company Trident Enterprises Ltd. Two of those aircraft were sold to MG Kenya Leasing Limited and leased back to the Mauritius company, which then subleased them to Dac Aviation (EA) Limited, a Kenyan company and subsidiary of DAC Aviation International. DAC did not reply to ICIJ’s requests for comment.

Read the 2012 board resolutions of Trident Enterprises Limited.

3. SSM Holdings Mauritius Limited and SSM Investments Mauritius Limited (3,746 miles)

Head office: Bangkok, Thailand
Distance to Mauritius: 3,746 miles
Industry: Hospitality

In 2010 Craig Cogut, the founder and CEO of Connecticut-based investment firm Pegasus Capital Advisors, asked Conyers for background on Mauritian companies SSM Holdings Mauritius Limited and SSM Investments Mauritius Limited. Cogut was considering investing in Six Senses, a chain of luxury resort hotels and spas headquartered in Bangkok that was using several companies in Mauritius to structure its multiple investments.

Both SSM Holdings and SSM Investments acquired shares in spas in Thailand. They had the same shareholding partner, Six Senses Mauritius Ltd, and one of their directors was Indian hotelier Sonashah “Sonu” Shivdasani, the chairman and CEO of the international Six Senses chain.

By the end of 2011, Six Senses Mauritius, which owned the Six Senses and Evason trademarks, held intellectual property rights for spas operating in other countries and had signed management, marketing and other contracts for tourism operations in Spain, the United Arab Emirates, Jordan, the Maldives, Oman, Thailand, Kuwait, Fiji, the United Kingdom, Sri Lanka, Egypt, Portugal, Malaysia, Turks and Caicos and India, among others.

Six Senses Mauritius sold its interests in the eponymous brand to Pegasus in 2012. The same year, Pegasus founder Cogut established Sustainable Luxury Mauritius Limited, of which he was the beneficial owner. In 2019, his firm sold Six Senses to InterContinental Hotels Group, owner of the Crowne-Plaza hotel chain among others. Cogut and Pegasus did not respond to our questions.

Here is the shareholding structure of Six Senses as of July 2010, including Six Senses Mauritius Ltd, SSM Holdings Mauritius Limited, and SSM Investments Mauritius Limited.

4. MakeMyTrip Limited (3,592 miles)

Head office: Gurugram, India
Distance to Mauritius: 3,592 miles
Industry: Travel

Dubbed “the largest online travel company in India” and with a corporate office located close to New Delhi, MakeMyTrip is headquartered in Mauritius. It has several subsidiaries: MakeMyTrip (India) Private Limited (the corporate office); MakeMyTrip Inc. (USA); MakeMyTrip FZ LLC (UAE); Luxury Tours & Travel Pte Ltd (Singapore); Luxury Tours (Malaysia) Sdn Bhd; the Hotel Travel Group; the ITC Group; and the EasyToBook.com Group.

In 2010, the company listed its shares on the NASDAQ — codenamed  “Project Karma.” The Conyers law firm advised on Mauritian law as part of the public listing. The Mauritius company had a tax residency certificate, which allowed it to benefit from a double taxation treaty with India. MakeMyTrip did not respond to our questions.

Here are the details of MakeMyTrip’s share listing on the NASDEQ, which was codenamed “Project Karma.”

5. Persianas Ltd. (4,106 miles)

Head office: Lagos, Nigeria
Distance to Mauritius: 4,106 miles
Industry: Residential and commercial real estate development and management

The Mauritius company Persianas Ltd. was used in relation to “an investment structure involving assets of the Persianas Group in Nigeria”, according to Conyers documents. The Persianas Group is a Nigerian real estate development and management company that owns several shopping malls in Lagos and other cities under the brand name “The Palms.”

In 2012, Snap Blu Ltd., another company registered in Mauritius but owned by Nigerian businessman Adetayo Amusan, transferred its shares in Persianas to the International Finance Corporation (IFC), the private finance arm of the World Bank, and the IFC’s African, Latin American and Caribbean Fund. One of the law firms that facilitated the deal was Udo Udoma & Belo-Osagie, a Nigerian corporate law practice that at the time was headed by Nigeria’s current minister of budget and national planning, Udoma Udo Udoma.

Contacted about the case, Minister Udoma Udo Udoma directed ICIJ to the law firm, which declined to comment. Pierre Mejlak, the IFC’s spokesman, confirmed the investment in Persianas, noting that “only a very small amount of the investment ($1 million of ALAC’s $25 million investment) was made by purchase from Snap Blu Ltd.” Mejlak added that his organization was mindful of widely accepted international principles regarding the availability of information to tax authorities. “All applicable IFC investments must comply with our Policy on the Use of Offshore Financial Centers which follows Global Forum reviews on tax transparency standards,” he said.

Read the details of the investment structure in the equity completion checklist

Contributors to this story: Will Fitzgibbon, Richard H. P. Sia, Hamish Boland-Rudder, Fergus Shiel and Karrie Kehoe