Global IP holding companies in 2023
| 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% | 25.8% | 11.9% - 21% | 24.94% |
| 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 | €19,650 | €24,170 |
| 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% | 25.8% | 11.9% - 21% | 24.94% |
| 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 neutral jurisdiction 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 neutral 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
