Innovative Solutions

 

Varietas delectat


Royalty Receipt Schemes

In international practice it is common to use offshore companies for the ownership of intellectual property (author rights, patents, trade marks and so on). This is due to the fact that intellectual property is the most flexible type of the property, which makes it easy to hand over to a foreign owner. This is why there is a natural tendency to place this property in those jurisdictions where its exploitation (royalty fee for the rights of commercial use of intellectual property) suffers the lowest tax losses.

As most offshore zones have no tax agreements with developed countries, by paying royalties to the offshore company in the country where the income is paid, tax will be charged at the source. In some cases the tax payment can be avoided or the tax rate can be reduced if the company from a taxable country (where there is a tax agreement) can be used in a scheme as a transit element. In this case the offshore company, the owner of the intellectual property, gives an operating license to a transit company and then the transit company issues a sublicense to the final user. In particular Dutch companies are widely used as transit elements, because the Netherlands does not charge withholding taxes for outgoing royalty. As a result royalties are transferred to the offshore company without any additional losses.

Structure example:

A foreign company owns a patent (trademark). For this purpose it is possible to use a company from any tax-free offshore jurisdiction. According to the license agreement this company assigns the right to issue sublicenses to use this patent (trademark), in Russia for instance. The Dutch company receives royalty from Russia and pays it to the offshore company.

There are no withholding taxes in Russia under authority of the Double taxation avoidance agreement. In the Netherlands only the difference between received and paid royalty is tax charged. There is no withholding tax for outgoing royalties in the Netherlands. There is also no income tax and outgoing dividends for the offshore company to pay.

办公室及联系方法

nederland荷兰

+31 880 200 200

greatbritain 英国

+44 203 514 0590

switzerland 瑞士

+41 22 518 1066

germany 德国

+49 211 6355 6763

Cyprus 塞浦路斯

+357 25 030 331

Monaco 摩纳哥

+377 97 778 273

israel 以色列

+972 3763 1014

china 中国

+852 5808 3160

hong kong 香港

+852 5808 3160

curacao 荷属安的列斯

+599 9461 0274

BVI 英屬維爾京群島

+44 203 514 0590

Malta 马耳他

+31 880 200 200

Gibraltar 直布罗陀

+44 203 514 0590

Ireland 爱尔兰

+44 203 514 0590

UAE 阿联酋

+31 880 200 200

Belize 阿联酋

+31 880 200 200

mail E-Mail

该Email地址已收到反垃圾邮件插件保护。要显示它您需要在浏览器中启用JavaScript。

skype Skype

blaustein.pro

question 發送請求

Send

发送请求