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Cases · Tax, finance & assurance · International tax planning & transfer pricing

Hold IP in the right company and country

Which company and country should own our brands and patents?

WONE Global designs where the IP should sit, values and documents any transfer, checks the tax in each country involved and records the change of ownership with the IP offices.

Countries in the typical case Malaysia · Singapore · Indonesia · Thailand

The situation

What is happening

The group’s brands, patents and software are held wherever they happened to be created, with tax and control consequences.

What is at stake

IP held in the wrong place costs tax on royalties and makes licensing, financing and sale harder.

Who faces this

  • Corporations
  • Mid-sized companies
  • Private clients and families

A scenario

Consumer goods groupMid-sized company · from Malaysia · in Singapore, Indonesia, Thailand

Its brands are registered in whichever group company happened to file them.

Where it ends Brands held where they make sense.

A representative scenario of the work WONE Global coordinates, not a specific client’s matter.

Also asked as “IP holding company”“Moving IP to a new jurisdiction”“We are relocating an intellectual property holding structure”

The solution

How WONE Global handles it

WONE Global designs where the IP should sit, values and documents any transfer, checks the tax in each country involved and records the change of ownership with the IP offices.

Usually led by Trade marks, patents and brands, with Tax and structuring, Setting up and running a company and Accounting and annual filings.

Step by step, in the scenario

  1. Weeks 1-2IP held by each company mapped.
  2. Weeks 3-4Holding structure and royalty flows designed.
  3. Weeks 5-8Valuation and transfers.
  4. ThenIP offices updated.

Timings are typical. They depend on the countries, the authorities involved and how quickly documents are available.

Decisions

The decisions involved

  1. 01Which entity should own and license the IP
  2. 02Exit taxes, transfer pricing and substance requirements of moving it
  3. 03How licences back to operating companies will work

Outcomes

What you receive

  • A recommended ownership structure
  • Valuation and transfer pricing support
  • Intercompany licences and filings in place

This is a general guide. Your WONE Global professional confirms the work, timing and fees for your markets before anything starts.

Who handles it

Trade marks, patents and brands, market by market

The status of the lead service in the markets that matter for this case. A named WONE Global Partner acts under their own licence; where none is in place yet, WONE Global confirms availability before anything else.

  1. Indonesiain the typical case On request Availability confirmed before any work begins Bring a requirement →
  2. Malaysiain the typical case On request Availability confirmed before any work begins Bring a requirement →
  3. Singaporein the typical case On request Availability confirmed before any work begins Bring a requirement →
  4. Thailandin the typical case On request Availability confirmed before any work begins Bring a requirement →
  5. Poland WONE Global Partner Anna Pawlikowska · Partner Brief this Partner →
  6. Uganda WONE Global Partner Tony Galandi Kiire · Managing Partner Brief this Partner →
  7. India On request Availability confirmed before any work begins Bring a requirement →
  8. Saudi Arabia On request Availability confirmed before any work begins Bring a requirement →
  9. United Arab Emirates On request Availability confirmed before any work begins Bring a requirement →
  10. United Kingdom On request Availability confirmed before any work begins Bring a requirement →
  11. United States On request Availability confirmed before any work begins Bring a requirement →

Other markets: WONE Global covers 100 countries. Name yours in the requirement →

Anna PawlikowskaKraków · Poland

WONE Global Capability Partner · Poland

Anna Pawlikowska

Partner · Zacharzewski & Partners Law Office · Kraków

Legal Adviser. Co-founder of the Firm. Has been advising parties on technology contracts for more than a dozen years. Specialises in intellectual property law and new technologies. Provides day-to-day legal services to …

Tony Galandi KiireKampala · Uganda

WONE Global Capability Partner · Uganda

Tony Galandi Kiire

Managing Partner · Diamond Advocates · Kampala

Tony Kiire is the Founding and Managing Partner of Diamond Advocates, where he leads the Technology, Innovation, and Intellectual Property Law practice. He is also the founder of Lawtech Associates and Consult, the comp…

Katherin Diaz VelillaBogotá · Colombia

WONE Global Capability Partner · Colombia

Katherin Diaz Velilla

Complete profile

Co-Founder · V&V Associates · Bogotá

International tax attorney and strategic advisor with 12+ years across Colombia's DIAN, Ministry of Finance, Senate, Presidency, and EY. Co-founder of V&V Asociados. Specializes in cross-border tax structuring, transfer…

Mauro Tejada RamonQuito · Ecuador

WONE Global Capability Partner · Ecuador

Mauro Tejada Ramon

Tax & Legal Partner · G&G Auditores Independientes & Lex Fiscal Corp · Quito

Professional with 20 years of experience in Tax Administration, performing functions in the managerial and tax administration fields. Experience related to the fiscal field in the main sectors of the economy: Banking, c…

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