Togo vs Mauritius: which holding jurisdiction for African business?
Search for the best place to hold African assets and the answer comes back in one word: Mauritius. It is not wrong. But it is answering a different question from the one most West African business owners are actually asking, and the gap between those two questions is the whole point of this article.
We form companies in Togo. We could pretend Togo beats Mauritius across the board. It does not, and we will say plainly where Mauritius is the better choice. These are two different tools for two different jobs. The mistake is assuming one jurisdiction answers every holding question.
Where Mauritius genuinely wins
Mauritius has spent thirty years building an offshore financial centre, and it shows. For a pan-African portfolio funded by international capital, it is the established answer for good reasons:
- The treaty network. Mauritius holds double-tax treaties with more than forty countries, including major African economies. That network is the product: it lets a holding company pull dividends up from operating countries at reduced withholding rates and redeploy them across the group efficiently.
- Low effective tax on foreign income. A Mauritius Global Business company can achieve an effective rate near 3% on qualifying foreign-source income, with a mature partial-exemption regime built for exactly this purpose.
- Recognition. International investors, development finance institutions and fund lawyers know Mauritius. If you are raising a fund or taking institutional capital, an investor's counsel opens the data room already comfortable with a Mauritius topco.
- Financial-centre depth. Fund administrators, licensed management companies, custodians and a court system with offshore case law all sit in one place.
If your structure is a pan-African investment portfolio raising from international LPs and pulling income out of many countries toward a single treaty-efficient topco, stop reading and go to Mauritius. That is its job, and it does it well.
What Togo does not claim
We will not pretend Togo competes with that. Its treaty network is thin: a 1971 convention with France, plus the multilateral WAEMU tax convention that binds the eight member states. It is not a global fund domicile, it has no deep offshore-services industry, and no institutional investor is going to recognise a Togolese holding the way they recognise a Mauritian one. If any of those are your requirement, Togo is the wrong door.
So why would a serious operator hold anything in Togo at all? Because for a specific and very common structure, the Mauritius advantages are irrelevant and Togo's are decisive.
Where Togo wins: the in-zone operating layer
Consider the more typical West African group. A businessman in Abidjan owns operating companies in Côte d'Ivoire, Benin and Senegal. He is not raising from London funds. He wants to consolidate his own companies under one holding, reinvest across them, and set up a clean succession. For that structure, Togo is not the compromise choice. It is the better one.
Same currency, no exchange event
Côte d'Ivoire, Benin, Senegal and Togo share the CFA franc, pegged to the euro at 655.957 with a French Treasury convertibility guarantee, under one central bank (the BCEAO). Moving a dividend from the Abidjan company to a Togo holding is a domestic transfer inside a single monetary zone: no currency conversion, no spread, no exchange-control authorisation. Route the same profits to Mauritius and you convert CFA to another currency, cross an exchange-control boundary, and take the rate risk both ways.
One legal system across the group
OHADA uniform company law governs the Togo holding and each of its West African subsidiaries with the same statutes, the same share-transfer mechanics and a common court of arbitration in Abidjan. The holding and the operating companies speak one legal language. A Mauritius topco sits outside that system and has to reach into it.
The participation regime
This is the part almost no one explains correctly. Under Togo's tax code, dividends a Togo holding receives from subsidiaries seated in Togo or any ECOWAS state are 95% exempt where the parent holds at least 10%. On Togo's 27% corporate rate, that is an effective rate of about 1.35% on regional subsidiary dividends. Qualifying holding companies are also exempt from corporate tax on gains from disposing of participations, where at least 60% of the portfolio is WAEMU companies. For a group whose subsidiaries are all in the ECOWAS zone, that is a genuinely efficient, and defensible, result.
Clean standing, no conduit optics
Togo appears on no FATF grey list and no EU list. A Mauritius structure used by a West African resident to hold West African assets can attract the opposite scrutiny: Senegal unilaterally terminated its tax treaty with Mauritius in 2020 over concerns about conduit abuse, and WAEMU tax authorities look hard at Mauritius vehicles interposed by their own residents. Holding West African assets through a West African company raises none of those questions.
The comparison, side by side
| Factor | Mauritius (GBC) | Togo (SARL / SAS holding) |
|---|---|---|
| Treaty network | 40+ double-tax treaties | Thin: France (1971) + WAEMU multilateral convention |
| Effective tax on regional dividends | ~3% on qualifying foreign income | ~1.35% on ECOWAS subsidiary dividends (95% exempt) |
| Moving funds in from a WAEMU opco | Currency conversion + exchange-control boundary | Same currency, one central bank, no FX approval |
| Legal alignment with subsidiaries | Outside OHADA; reaches in | Same OHADA law across all 17 states |
| Recognition by international investors | High; a known fund domicile | Low; not a global fund vehicle |
| List / reputation status | Reputable, but conduit optics for regional residents | No FATF/EU listing; a local company holding local assets |
| Setup cost & time | Higher; licensed management company required | Lower; days, from a Lomé agent |
| Best use | Global/treaty holding of a pan-African portfolio with international capital | Consolidating a WAEMU/ECOWAS operating group inside the zone |
Many groups should use both
The framing that treats this as Togo or Mauritius misses how larger structures actually work. A Togo holding can sit as the in-zone operating layer, consolidating the West African subsidiaries close to the assets in the local currency and legal system, while a Mauritius company sits above it as the international layer that faces investors and holds the treaty network. Each does what it is good at. The Togo layer is not a downgrade from Mauritius; it is the floor Mauritius is not designed to stand on.
How to decide
Ask one question: where does the money live, and where is it going? If your operating companies are in the WAEMU/ECOWAS zone and the goal is to consolidate, reinvest and pass them on, hold them in Togo, in the same currency and law, at about 1.35% on the dividends. If you are assembling a pan-African portfolio for international investors and need the treaty network and the recognition, hold it in Mauritius. If you are doing both, build both, each in its place. Our guide to the WAEMU holding company works through the in-zone structure in detail, and our Togo vs Seychelles comparison covers the operating-company-versus-offshore-shell question from the other side.
Consolidating a West African group?
Tell us where your companies are and what you want the holding to do. We will tell you whether Togo is the right layer, and where it is not.
General information as at July 2026, not legal or tax advice. Provisions referenced: CGI Togo arts. 93, 107; Règlement n°08/2008/CM/UEMOA. Mauritius figures are indicative of the Global Business regime and depend on substance and activity; confirm current treatment with a licensed Mauritius adviser. Figures change; we correct this page when they do.