Self-attention has greatly contributed to the success of the widely used Transformer architecture by enabling learning from data with long-range dependencies. In an effort to improve performance, a gated attention model that leverages a gating mechanism within the multi-head self-attention has recently been proposed as a promising alternative. Gated attention has been empirically demonstrated to increase the expressiveness of low-rank mapping in standard attention and even to eliminate the attention sink phenomenon. Despite its efficacy, a clear theoretical understanding of gated attention's benefits remains lacking in the literature. To close this gap, we rigorously show that each entry in a gated attention matrix or a multi-head self-attention matrix can be written as a hierarchical mixture of experts. By recasting learning as an expert estimation problem, we demonstrate that gated attention is more sample-efficient than multi-head self-attention. In particular, while the former needs only a polynomial number of data points to estimate an expert, the latter requires exponentially many data points to achieve the same estimation error. Furthermore, our analysis also provides a theoretical justification for why gated attention yields higher performance when a gate is placed at the output of the scaled dot product attention or the value map rather than at other positions in the multi-head self-attention architecture.