PATENTS · INVENTIONS
Patents and inventions
Holding patent rights in Cayman entity with licensing to subsidiary operating companies. Royalty payments, transfer pricing documentation, OECD-compliant rates.
More details06 IP structures OECD BEPS-compliant
Intelligent
property -
ownership and royalties.
Structuring of patents, trademarks, copyrights, software and domain names through Cayman IP holdings. Tax neutrality, OECD BEPS-compliance, license flows and asset protection from corporate risks.
IP categories
Six asset classes -
one institutional focus
Cayman Islands provides a universal legal infrastructure for all types of intellectual property - from classic patents to modern software and data assets. Since 2019, the economic substance requirements clearly define the parameters: substance works - structure works.
TRADEMARKS · BRANDS
Trademarks and brands
Centralized brand ownership through Cayman entity. Licensing of national subsidiaries, protection of brand value, unified management of IP-portfolio.
More detailsCOPYRIGHT
Copyright
Literary, musical, audiovisual works. Software copyright. Licensing through distributor agreements, royalty mechanics.
More detailsSOFTWARE IT
Software and SaaS rights
IP holding for SaaS code base, ML/AI models, databases. Licensing to a group through subscription fees or per-seat licenses. Standard in the IT industry.
More detailsDOMAINS DIGITAL
Domain names
Premium domains as an asset. Cayman holding owns domain portfolio, licenses use to local operating entities. Confidentiality of ownership.
More detailsDATA · DATABASES
Databases and data
Sui generis database rights (under EU law). Customer data, training datasets for AI, proprietary research. Cayman as a neutral data holder.
More detailsIP-Holding Cayman 2026
- Basic structure
- Exempted Company / LLC
- Corporate tax
- 0%
- Withholding on royalties
- 0% (outgoing)
- Substance requirements
- ES Test (DEMPE functions)
- Setup (entity + IP transfer)
- $15 000 — 35 000
- Annual operating
- $25 000 — 80 000
- BEPS Action 5 compliance
- OECD nexus approach
- Minimum substance
- Reasonably adequate
- DEMPE documentation
- Required
Why do you need an IP holding?
Four main
tasks IP structuring
Transferring IP to a separate holding company is not a “tax scheme”, but primarily a tool for asset protection and centralized management. Tax advantages are a pleasant side-effect with proper structuring.
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Asset protectionAsset firewall
IP in a separate entity is protected from operational risks of subsidiaries (litigation, bankruptcy, regulatory sanctions). Bullet-proof firewall between valuable asset and operations.
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Centralized managementCentralization
One portfolio managers instead of distributed IP rights in several jurisdictions. Unified licensing strategy, consistency brand, R&D coordination.
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Licensed streamsRoyalties
Properly structured licenses to operating subsidiaries create legitimate revenue streams. Transfer pricing on arm's length basis. Cayman did not add cost layer - but enabling structure.
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Exit and saleExit-ready
IP-portfolio in standalone entity - clean asset for sale separately from operations. Strategic buyers can acquire IP without operational liabilities. Higher exit valuations.
BEPS Action 5 OECD
Substance - critical
important after 2019
Until 2019, Cayman IP holdings were “light” structures without substance. Since January 1, 2019, the Economic Substance Act has been in force, which specifically identifies IP business as a relevant activity with the most stringent substance requirements. Without substance, the structure does not work.
Development
IP creation/development. R&D activities, prototype development, software engineering. Must involve the Cayman entity (not just third party contractors).
Enhancement
Improvement and development of IP. Updates, new features, expansions of IP rights. Decisions must be made on the islands by qualified personnel.
Maintenance
Maintaining IP rights: renewal of patents, defending trademarks, monitoring infringement, prosecution. Reasonable adequate substance in jurisdiction.
Protection
IP rights protection. Litigation strategy, enforcement actions, IP audits. Mandatory involvement of Cayman entity in strategic decisions.
Exploitation
Commercial exploitation of IP. Licensing strategy, royalty negotiations, business development. Real commercial activity on the islands.
High-risk IP
“High-risk IP business” (e.g. acquired IP without history, unrelated party transactions) - increased substance requirements and presumption of verification by the regulator.
Re-domiciliation · transfer of service
Company transfer
on service to us
Already registered a Cayman entity, but are unhappy with your current CSP (Corporate Services Provider)? Transferring services to us is a standard procedure, takes 2-3 weeks, without losing the legal continuity of the company.
- 1KYC and due diligence3-5 days
Standard set of documents for the company, directors, UBO. We re-register without the need to recreating CIMA registrations.
- 2Termination with previous CSP5-10 days
Signing a notice about termination of services. Receiving all corporate documentation (Memorandum, Articles, meeting minutes, BO register, ES filings).
- 3Translation of registered office and agent3-5 days
Filing in the Companies Registry about changing the registered office to our address (Cricket Square). Appointing us as registered agent.
- 4BO-register update and CIMA notification5-7 days
Update of the BO register, CIMA notification if the structure is regulated (fund, VASP, bank, insurance, trust company).
Re-domiciliation parameters
- Deadlines
- 2-3 weeks
- Cost
- $3 500 — 6 500
- Saving entity
- Full (same CIN)
- Contracts and assets
- Not affected
- CIMA license
- Saved
- Tax Exemption
- Saved
- Banking accounts
- Not affected
- Approval
- Without cabinet approval
Are you structuring your IP?
Request personal analysis
A lawyer partner will study your IP portfolio, current structure and offer the best option with substance, BEPS-compliance and transfer pricing analysis. Free consultation under NDA.