International Royalty Structures

ATC Corporate Services can assist clients to structure the ownership and international licensing of their intellectual property rights to minimize their global tax liability on royalty payments.

Without careful tax planning, the owners of valuable intellectual property rights (such as patents, trademarks, copyrights or image rights) can find that their profits from royalties are severely eroded by local withholding taxes applied by many countries around the world.

The ATC Group is represented in many international jurisdictions, including those jurisdictions that provide tax benefits to owners, licensors or users of intellectual property rights (“IP rights”). Therefore, ATC is the ideal partner to assist its clients in reducing their global tax liability by structuring the ownership and licensing of IP rights. Tax reduction can be achieved by strategically allocating the ownership of IP rights to a jurisdiction with low or no tax on received royalties. In many cases an intermediate licensing company in (another) jurisdiction that is party to favorable tax treaties is interposed between the IP-owning company and the ultimate user of the IP rights.

Both the IP owning company and intermediate licensing company can be (indirectly) owned by a client and be fully serviced by ATC Corporate Services, in the same manner that companies with other business purposes are serviced by ATC. However, for those clients who prefer to use an intermediate licensing company that is independent from both the IP owner and the end-user, ATC also offers the services of its fully owned Dutch intermediate licensing company “Hollandsche Maatschappij voor Licenties en Octrooien B.V.” (HMLO).

Follow these links to find more information on Dutch licensing opportunities and on the ATC-owned intermediate licensing company HMLO.

Please click here if you have any specific queries about our international licensing and royalty structure services.

© ATC Group 2005 disclaimer | due diligence