| Intellectual Property Holding Company It is increasingly common to find companies being formed to act as the international sub licensee for important intellectual property rights (patents, copyrights, etc.). This offshore company can then enter into sublicensing arrangements around the world for the sublicensed intellectual property. Royalties paid for the usage of the intellectual property can attract withholding tax at the source, and the existence and use of such an offshore holding company may permit tax rate reductions. |