Tech business structure

PinkPanther

New Member
Feb 7, 2022
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Hi all,

I am new here, first time as an individual doing offshore companies and have been reading here for some time now.
Since a few months, I am working on a new business in software development (including and not limited to cryptocurrency related software such as traders, exchanges etc.).
We are currently in the formation research process and looking for some thoughts on our company structure.

Our main goals:
- Pay as little tax as possible
- Protect our IP (software)
- Add some extra security (read: anonymity + liability)

We are thinking of achieving these goals with the following structure, please note that we are Dutch residents (NL):
-- Dutch Holding company (Dutch BV / Ltd) (multiple shareholders)
---- Dutch subsidiary operating company (Dutch BV / Ltd)
---- UK LLP (95% ownership by the dutch holding, rest of other dutch companies to form the partnership)
------ Seychelles IBC

This would allow us to use the Seychelles IBC as operating company for the distribution of our software (licensing) and would allow the Seychelles IBC resell the software through partners.
The LLP will be a pass-through vehicle, as the Dutch holding should be able to collect the royalties for the distribution from the Seychelles IBC via the LLP. Any extra capital gains, such as investments of the money in crypto, can be taxed at 0% in the IBC.
All IP assets will be protected in the Dutch holding company as we develop the software in The Netherlands.
Lastly, since we will use the IBC as the "customer" facing organisation, we would not expose our names to our customers.

Any thoughts on this?

Thanks in advance!
 
PinkPanther said:
Hi all,

I am new here, first time as an individual doing offshore companies and have been reading here for some time now.
Since a few months, I am working on a new business in software development (including and not limited to cryptocurrency related software such as traders, exchanges etc.).
We are currently in the formation research process and looking for some thoughts on our company structure.

Our main goals:
- Pay as little tax as possible
- Protect our IP (software)
- Add some extra security (read: anonymity + liability)

We are thinking of achieving these goals with the following structure, please note that we are Dutch residents (NL):
-- Dutch Holding company (Dutch BV / Ltd) (multiple shareholders)
---- Dutch subsidiary operating company (Dutch BV / Ltd)
---- UK LLP (95% ownership by the dutch holding, rest of other dutch companies to form the partnership)
------ Seychelles IBC

This would allow us to use the Seychelles IBC as operating company for the distribution of our software (licensing) and would allow the Seychelles IBC resell the software through partners.
The LLP will be a pass-through vehicle, as the Dutch holding should be able to collect the royalties for the distribution from the Seychelles IBC via the LLP. Any extra capital gains, such as investments of the money in crypto, can be taxed at 0% in the IBC.
All IP assets will be protected in the Dutch holding company as we develop the software in The Netherlands.
Lastly, since we will use the IBC as the "customer" facing organisation, we would not expose our names to our customers.

Any thoughts on this?

Thanks in advance!
Click to expand...
Hi,

Would your income derive from the licensing of the software?
 
Yes, we have been thinking about this, but we don't understand the Cypriot writings and since we use the LLP as proxy we thought it would be the best alternative option.
 
PinkPanther said:
Yes, we have been thinking about this, but we don't understand the Cypriot writings and since we use the LLP as proxy we thought it would be the best alternative option.
Click to expand...
Happy to PM you to discuss about the Cyprus option, as it is one of the best IP related regimes in the EU at the moment.
 
CyprusLaw said:
Happy to PM you to discuss about the Cyprus option, as it is one of the best IP related regimes in the EU at the moment.
Click to expand...
Inside mentor group gold you can just PM people if you think they could need your help, no need to ask 🙂

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