PATENTS · INVENTIONS
Patents and inventions
Holding patents through a Cayman company with licensing to operating subsidiaries. Royalty payments, transfer pricing documentation, rates in line with OECD standards.
More details06 · IP structures · OECD BEPS-compliant
Intellectual
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
The 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 a Cayman company. Licensing of national subsidiaries, protection of brand value, unified management of the intellectual property rights portfolio.
More detailsCOPYRIGHT
Copyright
Literary, musical, audiovisual works, software rights. Licensing through distributor agreements with a transparent royalty calculation mechanism.
More detailsSOFTWARE · IT
Software and SaaS
Holding rights to source code, machine learning and artificial intelligence models, databases. Licensing to group companies through subscription or by number of users. The standard arrangement for the IT industry.
More detailsDOMAINS · DIGITAL
Domain names
Premium domains as a standalone asset. A Cayman holding owns a portfolio of domains and licenses their use to local operating companies. Confidentiality of ownership.
More detailsDATA · DATABASES
Databases and data
Sui generis database rights under European law. Customer data, training datasets for artificial intelligence, results of proprietary research. The Cayman Islands — a neutral jurisdiction for holding data rights.
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
- Reasonable adequate
- DEMPE documentation
- Required
Why you need an IP holding
Four core tasks of
structuring intellectual property rights
Transferring intellectual property rights into a separate holding company is not a “tax scheme”, but first and foremost a tool for asset protection and centralized management. Tax advantages are a pleasant side-effect of a properly built structure.
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Asset protectionAsset firewall
Intellectual property rights held in a separate company are protected from the operational risks of subsidiary structures: lawsuits, bankruptcy, regulatory sanctions. A reliable legal barrier between the valuable asset and operational activities.
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Centralized managementCentralisation
A single portfolio manager instead of scattered rights across several jurisdictions. A consistent licensing policy, brand unity, coordination of research and development.
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License flowsRoyalties
Properly drafted licenses for operating subsidiaries create legitimate income streams. Transfer pricing on market terms (the “arm's length” principle). A Cayman structure does not add extra costs — it creates the conditions for efficient operation.
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Exit and saleExit-ready
A portfolio of intellectual property rights in a separate company is a clean asset that can be sold independently of the operational part of the business. Strategic buyers acquire the rights without operational obligations. A higher valuation on exit from the business.
BEPS Action 5 · OECD
Substance — critically
important after 2019
Until 2019, Cayman IP holdings were “light” structures without substance. Since 1 January 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
Creation and development of intellectual property rights: research and development activities, prototype development, writing program code. Must take place with the involvement of the Cayman company, not solely by third-party contractors.
Enhancement
Improvement and expansion of rights: updates, new features, broadening the scope of protection. Decisions must be made on the islands by qualified personnel.
Maintenance
Keeping rights in force: renewal of patents, protection of trademarks, monitoring infringements, prosecution of infringers. Sufficient economic presence in the jurisdiction.
Protection
Protection of intellectual property rights: litigation defense strategy, enforcement actions, regular portfolio audits. The Cayman company necessarily participates in strategic decision-making.
Exploitation
Commercial use of rights: licensing policy, negotiation of royalty rates, business development. Real commercial activity is conducted on the islands.
High-risk IP
High-risk intellectual property activities — for example, acquired rights with no history of creation or transactions between unrelated parties — require an increased economic presence and entail enhanced scrutiny by the regulator.
Re-domiciliation · transfer of service
Transferring your company
to our service
Already registered a Cayman entity, but unhappy with your current CSP (Corporate Services Provider)? Transferring service to us is a standard procedure, takes 2-3 weeks, without losing the company's legal continuity.
- 1KYC and due diligence3-5 days
A standard set of documents on the company, directors and UBO. We re-register without the need to recreating CIMA registrations.
- 2Termination with the previous CSP5-10 days
Signing a notice of termination of services. Receiving all corporate documentation (Memorandum, Articles, meeting minutes, BO register, ES filings).
- 3Transfer of registered office and agent3-5 days
Filing in the Companies Registry to change the registered office to our address (Cricket Square). Appointing us as registered agent.
- 4BO-register update and CIMA notification5-7 days
Updating the BO register, notifying CIMA if the structure is regulated (fund, VASP, bank, insurance, trust company).
Re-domiciliation · parameters
- Timeframe
- 2-3 weeks
- Cost
- $3 500 — 6 500
- Preservation of entity
- Full (same CIN)
- Contracts and assets
- Not affected
- CIMA license
- Preserved
- Tax Exemption
- Preserved
- Banking accounts
- Not affected
- Approval
- Without Cabinet approval
Structuring IP?
Request a personal analysis
A partner lawyer will study your IP portfolio and current structure and propose the optimal option with substance, BEPS-compliance and transfer pricing analysis. Free consultation under NDA.