Conduits of Capital

ANNEX 1: CATALOGUE OF FINANCIAL CENTRE ATTRIBUTES 25
General Information
Dublin Mauritius Dubai Botswana
Number of asset managers / promoters 431 135 14 14
Number of fund administrators 60
135 (the 'manager' is the
administrator)
12 0
Number of law firms 30 22 16 Approx. 6 with cap mkt expertise
Number of audit firms 10 28 16 19
Custodians 23 6 13 3
Number of funds registered
Membership of regional blocs
Tax Environment
1,136 (5,224 inc. sub funds)
Listed 3,400
European Union
600 1,600 (foreign funds) 16 domestic, 60 foreign
African Union, the
Southern African
Development Community
(SADC), the Common
Market for Eastern
and Southern Africa
(COMESA) and IOR-ASC
Gulf Cooperation Council
Southern African Development
Community (SADC)
Fund
No tax on income or gains. No
asset tax.
No capital gains tax.
Deemed tax credit of 80%
of theoretical WHT = 3%
tax on ordinary income
but with DT offset.
No capital gains tax. No tax
on income. No withholding
tax.
Funds in BIFSC: no capital
gains tax. No withholding tax
on payments of interest or
dividends to non-residents (15%
for residents).
Management company 12.50%
15% or alternative of
7.5% of accounting profits
or 10% of dividends (see
detail)
Exemption for 15 years from
formation and extension
further 15 years if corporate
taxes introduced
If BIFSC based, not subject to
capital gains tax, withholding tax:
15% corporation tax. Can offset
foreign withholding tax
Value added tax Exempt No No Exempt in BIFSC
Other applicable taxes None No Unclear
Stamp duty No No No No
Double tax treaties in effect 62 (see annexe) 34 (see annexe) 60
Name of regulatory body
Applicable Law
Central Bank of Ireland. The
Central Bank of Ireland is
responsible for the regulation
of most financial service firms
(financial service providers) in
Ireland; including funds, fund
service providers (including
managers, promoters and
administrators).
No specific fund law but
amended unit trust act and
company act together with
adoption of EU directives
relating to UCITS.
Mauritius Financial
Services Commission.
The Financial Services
Commission, Mauritius
(FSC) is the integrated
regulator for the fin-ancial
services sector other
than banking. (NB GBC
set up under Companies
Act) The FSC licenses,
regulates, monitors and
supervises the conduct
of business activities in
the non-banking financial
services sector.
Financial Services Act
2007. Securities collective
investment schemes
and closed-end funds
regulations 2008.
Dubai International Finance
Centre (DIFC) is a separate
jusrisdiction with its own
laws. Dubai Financial
Services Authority is the
independent regulator
of financial and ancillary
services conducted in or
from the DIFC, responsible
for managing or distributing
Collective Investment Funds
(Funds).
DFSA Collective Investment
Fund Law 2006.
13 in place, 6 due for ratification,
6 in process
Botswana IFSC is governed by
laws of Botswana; BIFSC status
is conferred by tax certificate.
Non-Bank Financial Institutions
Regulatory Authority regulates
non-banks including collective
investment schemes and their
managers.
Collective Investment
Undertakings Act Chapter 56:
09. New CIU Bill drafted that
will enable closed ended funds
and partnership structure funds.
25
Source: Codogan Financial, Developing a private equity investment management industry in Rwanda (2011).
Conduits of Capital – Onshore Financial Centres and Their Relevance to African Private Equity
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