Global IP holding companies in 2022

Intermediate holding companies SINGAPORE CYPRUS NETHERLANDS SWITZERLAND LUXEMBOURG
Our ranking in order of preference 1 2 3 4 5
Summary at a Glance
Best city/province for registration? Singapore Limassol Amsterdam Nidwalden Luxembourg
Recommended type of business entity? LLC LLC LLC GmbH SARL
Standard corporate income tax rate? 17% 12.5% 25% ~12.5% 28%
Tax rate on royalties and IP income? 10% up to 2.5 5% 9% 6%
Resident director required? Yes No* Yes Yes Yes
Access to the Madrid Protocols? Yes Yes Yes Yes Yes
Global rank for IP protection? 6/128 41/128 9/128 5/128 3/128
Our Client must travel? No No No No No
Total engagement period? 2 months 2 months 3 months 2 months 2 months
Standard engagement costs? US$12,030 €9,535 €12,360 €20,650 €19,170
Incorporation requirements
Registered address required? Yes Yes Yes Yes Yes
Lease for office space required? No No No No No
Corporate bank account required? Yes Yes Yes Yes Yes
Suggested corporate bank account? DBS Bank of Cyprus ABN Amro UBS RCB
Minimum number of directors? 1 1 1 1 1
Resident director(s) required? Yes No* Yes Yes Yes
Minimum number of shareholders? 1 1 1 1 1
Minimum paid-up capital required? US$1 €1 €1 €18,500 €12,400
Allowed to issue preference shares? Yes Yes Yes Yes Yes
Public register of shareholders & directors? Yes Yes Yes Yes Yes
Tax and accounting considerations
Will the company be tax resident? Yes Yes Yes Yes Yes
Standard corporate income rate? 17% 12.5% 25% 11.5-24.2% 28%
License box scheme available? Yes Yes, IP box Yes, Innovation Box Yes, Nidwalden License Box Yes, Luxembourg License box
Can IP income be exempt from corporate tax under certain criteria? No Yes No No No
Tax credit/incentives for R&D? Yes Yes Yes Yes Yes
Tax on transfers of patents and other IP? No No No No No
Standard withholding tax on dividends? 0% 0% 15% 35% 15%
Does the entity have DTAA access? Yes Yes Yes Yes Yes
Web link list of available DTAAs? Here Here Here Here Here
Special tax regime for holding companies? Yes No No Yes Yes (SOPARFI and SPF)
Trading income allowed for holdings? No Yes Yes Yes No
For Holding Company to enjoy exemptions, does it have to:
i) Have resident director in the country? Yes Majority* Yes Yes Yes
ii) Have a local staff? No No No No No
Required % ownership for subsidiaries? 20% At least 10% 5% 10% 10%
Controlled Foreign Corporation (CFC) rules applicable? No No No, except in this case No Yes
Does the country have a tax haven list? No Yes Yes No No
Compliance considerations
Annual tax return to be submitted? Yes Yes Yes Yes Yes
Annual financial statements required? Yes Yes Yes Yes Yes
Statutory audit required? No Yes No No No
Must register for VAT? Yes Yes Yes No No
Can do business and hire locals? Yes Yes Yes Yes Yes
Will the country banks apply FATCA? Yes Yes Yes Yes Yes
Will the country implement CRS? Yes Yes Yes Yes Yes
Blacklisted tax haven jurisdiction? No No No No No
Bank account characteristics
Healy Consultants' preferred bank? DBS Bank of Cyprus ABN Amro UBS RCB
Do I travel to open the bank account? Yes No No No No
Recommended minimum deposit? US$50,000 €2,000 €1,000 €5,000 €5,000
Multi-currency corporate bank account? Yes Yes Yes Yes Yes
Corporate credit card? No Yes Yes Yes Yes
Corporate ATM card available? Yes Yes No Yes Yes
Bank rating by World Economic Forum? 5/144 126/144 60/144 20/144 12/144
Ease of getting credit? (by WEF)? 4/144 109/144 49/144 28/144 6/144
Quality of online banking? Excellent Excellent Excellent Excellent Good
Logistics considerations
Availability of engineers and R&D staff? Excellent Excellent Excellent Excellent Average
Average monthly salary for R&D engineer? US$5,660 €2,100 €5,295 €8,900 €5,000
Universities included in Shanghai ranking? 83 None 12 8 0
Virtual office services available? Yes Yes Yes Yes Yes
Allowed to make sales to foreign Clients? Yes Yes Yes Yes Yes
Allowed to make sales to local Clients? Yes Yes Yes Yes Yes
Local sales subject to tax? Yes Yes Yes Yes Yes
Can the entity hire local staff? Yes Yes Yes Yes Yes
Can the entity hire expatriate staff? Yes Yes Yes Yes Yes
How long to secure a work permit? 4 weeks 3 months 4 weeks 3 months 2 months
Personal tax for residents? (range) 2%-20% 0%-35% 36-52% 24%-45% 0-40%


*Legally, no resident directors are mandatory in Cyprus, however to decrease probability of foreign authorities challenging the tax-residency status of Cyprus company, one will need to i) have majority directors based in Cyprus or ii) execute board resolutions in Cyprus

Contact us

For additional information on our corporate banking services, please contact our in-house country expert, Mr. Simon Guidecoq, directly:
client relationship officer - Simon