IP & Transaction Advisory

Intellectual property is mobile in a way that factories are not, which is exactly why tax authorities scrutinise it. The country that owns the IP collects the royalty, and the country that uses it deducts the payment — subject to treaty and transfer pricing. We map the development, ownership and licensing chain against the group's footprint so the royalty route is both efficient and defensible.

A structure that lacks substance in the holding country will not survive a residency or transfer pricing challenge. We make sure the IP owner genuinely makes the decisions and bears the risks, not just invoices the royalty.

Each licence in the chain is a separate transaction at arm's length. We set the royalty rate at each step, document the functions of each licensor, and route the payments through the treaty network so withholding is reduced on a defensible basis.

Cost contribution arrangements let multiple group entities share the cost and risk of developing IP, then each own a share of the result. We structure these against the OECD guidance so the economics — not the tax — drive the split.

Moving IP between countries is a transfer at arm's length and must be valued. We prepare the valuation, document the method, and report the transfer in both the exit and the entry country so the migration is transparent.

Dematerialisation — moving IP out of a country without a taxable transfer — is closely watched. We test whether the planned steps amount to a transfer, and if they do, we value and report it rather than leaving it to be discovered.

Several countries we serve offer R&D credits or patent box regimes that tax qualifying IP income at a reduced rate. We identify where the group's development activity qualifies, build the substance to support the claim, and align it with the transfer pricing so the benefit is not undone on audit.

An IP ownership and licensing map, royalty and licence terms, a transfer valuation, the supporting documentation, and alignment with transfer pricing and substance. The deliverable is an IP chain where every link is defensible.