Case studiesBusiness
A three-country software group, from 26% to 14%
The group's IP sat in a holding company with no people behind it. We moved it to where the team works, added real substance, and documented the whole thing to file.
2.4EUR m / year
recurring tax saving
- Client
- Software group operating in three countries
- Countries
- EE · NL · DE
The situation
The group's IP sat in a holding company with no people behind it, licensed to operating entities that had built the software themselves.
The group effective rate was around 26%, and the licensing arrangement would not have survived a serious review.
What we did
- 1Moved the IP to where the development team actually works.
- 2Put real substance behind the remaining holding entity.
- 3Rewrote the intercompany agreements to match what each company genuinely does.
- 4Documented the transfer pricing, ready to file.
The outcome
Group effective rate down from roughly 26% to 14%, about EUR 2.4m a year.
A defensible file behind it, rather than a position nobody wanted to be asked about.
Completed engagements are marked as such; examples marked "Illustrative" show how a typical situation is handled and are not client results. Names, sectors, figures and timings are generalised or omitted so that no client is identifiable. Every result depends on that client's facts. Nothing here predicts what your position would produce, and nothing here is advice.
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