We advise companies engaged in IP development and commercialization on structuring their operations to qualify for the 0% Corporate Tax rate. Our services include analyzing business models, ownership of intellectual property, and revenue streams to ensure compliance with the Nexus Ratio Test, Adequate Substance requirements, and Transfer Pricing rules. We develop tailored recommendations to localize R&D activities, document development expenditures, and structure IP ownership efficiently, ensuring tax optimization and regulatory compliance.
