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Royalty Routing – from ILS

Royalties are the payment of licence fees or commissions by one individual or entity to another for the use of intellectual property (IP).

Intellectual property can take several forms:
  • Patents that protect inventions or new processes
  • Trademarks that relate to the names of the products and perhaps also their design and packaging
  • Copyright which attaches to any original creative idea expressed in words or pictures
  • Image rights
Our aim is to generate the income arising from these rights in the most tax efficient manner possible.

How it works:
  • The client owning the intellectual property donates or sells it to an offshore owning company. This is ideally done when the property is of little or no value
  • The offshore company licences some or all of the rights for the use of the property to an onshore intermediary or agency company created in a jurisdiction
  • The onshore intermediary company then exploits the rights by licensing their use in various countries
  • Royalty fees pass to the onshore intermediary company which may be subject to zero or a low withholding rate due to double tax treaty provisions
  • The onshore intermediary company retains a fee for the work done in negotiating contracts etc and will pay tax on this sum
  • Finally, the onshore intermediary company remits the balance to the offshore company free of any further withholding taxes
What ILS can provide:
  • Formation of companies and trusts
  • Use of our service companies as intermediaries
  • Assistance with contracts
  • Invoicing and accounting
  • Administration
  • Director and secretary services
  • Registered office facilities
  • Opening of bank accounts
  • Physical office facilities
Further information from Peter Beighton.