Tax planning for IP
Efficient tax planning is one of the most important-and often overlooked-components to protecting your intellectual property. Our international corporate tax group comprises a team of skilled lawyers located in our offices around the world who combine responsive, high-quality tax advice with an awareness of IP structures and any issues that may arise.
We believe that a successful tax planning structure should include:
- Centralized IP income in a low-tax jurisdiction with a high level of legal and tax system stability.
- Deduction of royalties and other cash flows at the level of operational entities, thereby decreasing local tax base.
- Reduced or no withholding tax on royalties and other cash flows.
- Flexible exit scenarios (e.g., low gains tax on sale of IP, making it an efficient target for subsequent acquisition).
Working with our corporate tax team of lawyers, we strive to find the most favorable IP holding company jurisdiction-in or outside of the US-in an effort to deliver a tax-efficient structure with a lower global effective tax rate.