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Bearing in mind that within the European Union there are no withholding taxes on IP royalty payments between one member state and another, we can suggest a number of countries where royalty income taxes are particularly advantageous.
CYPRUS The intellectual property royalty tax system in Cyprus changed as a consequence of the recommendations of the Organisation for Economic Co-operation and Development (OECD)'s Action 5 report, as well as the conclusions of the Ecofin Council, published on 8 December 2015. The legislation was amended to limit the companies that can benefit from exemptions for research and development (R&D), but the tax rate in Cyprus is still one of the most favourable in the EU for foreign companies wishing to license the use of IP to a Cyprus-resident company (intermediary), where that right is then sub-licensed to the end user. Overall, the effective tax on income from IP royalties should be less than 2.5%.
IRELAND In 2015, Ireland introduced an effective corporation tax rate of 6.25% on income derived from IP, based on an allowance for the research and development costs sustained by the company. By linking the two components in this way, Irish law encourages companies to conduct R&D directly, inside the EU — leading to the creation of IP — whereas it discourages them from buying licences without making a direct commitment to R&D.
BELGIUM Belgium has established a tax regime that works in favour of those with income deriving from acquired copyrights. This fiscal regime can have many different applications, and can be used to protect artworks as well as providing a useful tax concession for IT developers. Revenues deriving from royalties on IP rights are taxed at 15%. These revenues are not taken into account when social security contributions are calculated. Moreover, for imports these taxes are reduced by 50% due to the application of standard entry costs. The first 15,000 euros earned by a copyright holder in a year is therefore taxed at 7.5%, and the following 15,000 at 11.25%. This tax system applies to those with a total annual income of up to 56,450 euros.
THE NETHERLANDS Since 2010, IP revenues in the Netherlands have been taxed at just 5%. There is no income threshold, except with respect to patents. Patent holders can in fact have access to this tax system if their share of the expected income is between 30% and 70%, taking into account the total combined revenue from patents and other sources. These rates also apply to foreign companies that own intangible assets or companies that have obtained a research and development accreditation from the Dutch Ministry of Economic Affairs, if they are the holders of software IP or trade secrets. The only other limitation of this favourable tax regime is that it does not apply to marketing- and brand-related assets.
LUXEMBOURG Generally, corporation tax in Luxembourg is 29.22%, but on revenues from IP licensing it can be as low as 5.8%. This is due to a corporate income tax exemption of 80%. Interestingly, this exemption also applies to companies that have registered a patent to be used in connection with their own activities, which then calculate a fictional net income, as if they had received the income from licensing it.
ITALY Italy is a bigger market compared to the other countries discussed, and it can be a very attractive place for a company to invest in research and development, because since 2015 companies have been able to deduct income deriving from intellectual property from their taxable income base. The fiscal deduction was set at 30% in 2015, 40% in 2016 and 50% starting from 2017. Companies will therefore enjoy a substantial tax discount as a result of the reduction in their taxable income.
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Major industries in the country are motor vehicles, metallurgy, machinery and equipment, glass, armaments. The Industrial Production growth rate of Czech Republic is 15.9%.2.4% of population in the country are unemployed. The total number of unemployed people in Czech Republic is 255,006. Czech Republic produces 81,710 GW/h of electricity each year. Czech Republic emits 10.4 metric tons per capita of CO₂. On average, you would pay 1.67 USD for one liter of gasoline in Czech Republic. One liter of diesel would cost 1.17 USD.
Labour The total labor force of Czech Republic is 5,363,650 people, wherein 3% are working in agriculture, 39% are working in industry, and 58.% are employed in services. People in Czech Republic speak the Czech language.
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Legal translation is all about rendering translation services in the field of law. This includes translating contracts, agreements, articles of association (in case of company formation), as well as various business documents and blanks.
Legal translation is different from other forms of translation, as it relies on the utmost precision of conveying information and terminological correspondence, since incorrect translation may lead to significant legal incongruity, including law violations and lawsuits. This is the primary reason why legal translation services are provided by special business-support agencies like Confidus Solutions. Translator, with no preliminary knowledge of law-related linguistics, risks making a faulty contract translation, potentially incurring legal consequences to the business.
Business translations Business translations can be considered a sub-type of legal translations, dealing with contracts, agreements and other legally binding documents between two parties. Business translations are related to both law and economics, because most contracts operate with terms from both of these fields. As corporate documents often include not only initial documents (articles of association, shareholder agreement, etc.), but also documents related to daily business activities, high quality business translations are a must at all times, if you want to avoid unnecessary risks and lawsuits.
Possible translation challenges may include: names of legal forms, arising from the fact that many jurisdictions recognize different legal forms, which may correspond to each other to a greater or lesser extent. A single legal form in one country may be represented by several similar forms in another. When incorporating in a foreign jurisdiction, it is crucial to indicate such differences correctly in company registration documents, as it defines the scope and the nature of corporate structure and activities.
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Today Canada is the seventh largest economy. Many companies are owned by private entities, but the government participates in the healthcare system and oversees some services, such as public transport and the utility industry. The Canadian economy is very diverse and quite well developed.
Most of Canada's economy is international trade and export. Currently, the US is Canada's largest trading partner. In Canada, international trade accounts for almost 45% of GDP considering that free trade agreements between Canada and the US have dramatically increased trade by eliminating tariffs. Despite its relatively small population, Canada's economy is currently one of the most prosperous in the world.
All strategic industries of the country are very well developed. Although the agricultural sector is small, it takes advantage of Canada's numerous natural resources, which are scattered across the country. In view of this, Canada is an attractive destination for global businessmen and corporations. Canada's flexible tax legislation leaves room for the use of holding structures: the country is home to several large holding companies.
ATCO group ATCO group is a one of the biggest Canadian holding companies, having big net turnover and assets. Today this corporation employs almost 7 000 specialists of different professions. Holding’s subsidiary companies are diverse, but most of them are in either the gas / electricity or construction industries.
ATCO was founded in 1947, by S. Don Southern who gave a minority stake to his son Ron Southern, under the name Alberta Trailer Hire, renting fifteen utility trailers in the Calgary area.[3] As the company’s operations grew, they also began to sell trailers, first becoming the Alberta Trailer Company, then ATCO. By the early 1960s, the company had operations across North America and in Australia.
In 2004, with the deregulation of the retail energy industry in Alberta, ATCO sold the retail operations of ATCO Gas and ATCO Electric to Direct Energy Marketing Ltd.; ATCO Gas and ATCO Electric still operate as distributors (owning and operating the infrastructure that delivers natural gas or electricity in its service territories) but are no longer in the retail market. As part of the sale to DEML, DEML contracted call center and billing services from ATCO I-Tek.
DRI Capital DRI Capital Inc. is a local Toronto-based Canadian healthcare royalty fund manager, a kind of private fund. Holding company’s scope of duties includes purchasing robust and predictable royalty streams from already existing pharmaceutical medicine, thus, providing constant profit to the investors.
The holding was established back in year 1992. During first year of conducting business activity it quickly went public on the Toronto Stock Exchange and acquired a royalty interest in the innovative British biotechnology development company.
Great-West Lifeco Great-West Lifeco is mostly an insurance oriented Canadian holding company, operating on the territory of North America, Europe and Asia using 5 local subsidiaries around the world. Most of the businesses Great-West Lifeco has indirect control over are part of its largest subsidiary: The Great-West Life Assurance Company; the rest are supervised by the located in the United States subsidiary branch.
Onex Corporation Onex Corporation is a private owned equity investment company and holding structure located not far from Toronto, Ontario, Canada. In year 2016, the company had estimated $22 billion worth of net assets under its management. The company is headquartered in the Brookfield Place, Toronto, with several branches in New York City, New Jersey, and London.
The firm invests in a wide array of industries. Onex Corporation previously has demonstrated a specific interest in acquiring equity shares of the high-cost manufacturing industry companies and subsequently turning them into cheap, low cost suppliers.
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With regard to political and civil freedoms, North Korea is 3. Citizens in North Korea experience little to no civil liberties and political rights. Citizens are not free to express themselves and do not enjoy political freedom or a representative government. Countries with this political situation are dangerous for investment, as an authoritarian government may have outsize control over economic matters. The businesses of North Korea are 5 in terms of economic liberty. Citizens in North Korea are considered not free with regards to their economic decisions. The government prohibits all economic activities by citizens, and some illegal business activities could be punishable by imprisonment or even death. Investors should avoid countries that are not free economically, as the risks do not justify any potential gain. In terms of journalistic freedom, the media of North Korea is in a 5. In North Korea, journalists face a very serious situation. Censorship dominates all publications and the government controls the majority of media outlets. Journalists that express opinions against the government may be punished with fines, imprisonment, or death.
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Eritrea's logistics performance index is 2.08. It indicates mediocre performance - transit procedures are relatively unreliable, punctuality and safety of transported goods are often an issue, although such a system can work relatively well when traffic is not too heavy.
Customs performance is rated at 1.9. This indicates mediocre performance - although somewhat ineffective, clearing processes do not unduly discourage international business activity, occasionally fees and/or required documents can be unpredictable, long clearing times can also be an issue.
The infrastructure quality in Eritrea is rated at 1.68. It indicates mediocre quality - roads, railways, ports and other facilities are capable of handling some significant traffic, but not enough to ensure smooth transit at all times.
The quality of international shipping is 1.9. It indicates a mediocre performance - the services provided are reasonably attractive to foreign customers, and the price is right up there with the quality, which is still not very competitive.
The competence of logistics service providers is rated at 2.23. The providers are of mediocre competence - they can ensure a certain quality of their services, sometimes even outstanding, although their overall performance can still be deficient in many aspects.
Tracking options for shipments are rated at 2.01. It indicates mediocre performance - the tracking systems provide some information, which usually includes the most necessary subjects, such as the current location of a shipment, the arrival and departure dates and the status of a shipment; however, there is usually a lack of more detailed information on the status and multilingual accessibility options.
Tracking options for shipments are rated at 2.79. This indicates satisfactory performance - most shipments arrive on time and within scheduled time frames; late arrivals are still possible, albeit uncommon.
In Eritrea, 36.1% of the population has access to electricity. Eritrea has 13 airports nationwide. There are 701 internet hosts in Eritrea. The number of road vehicles per 1000 inhabitants in Eritrea is 551.
Road network The total road length in Eritrea is 4,010 km (2,492 miles). Of these, 0 km (0 miles) of roads are classified as freeways, dual carriageways, or freeways.
Gas price On average, one liter of petrol costs USD 3.33 in Eritrea. A liter of diesel would cost $1.1.
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Once the preparatory steps have been completed and all relevant decisions have been made, it is time to start registering the company. This process varies greatly by jurisdiction, so we can only provide general guidelines here.
First, contact your lawyers and start drafting the necessary documents. Most incorporation documents should be signed in front of a notary public, with signatures notarized (and apostilled if necessary). Document creation usually takes between one and five days. Also keep in mind that the initial deposits into the company's equity must be made before filing the documents with the commercial register. Banks usually open a temporary bank account solely for the purpose of depositing equity.
After all documents are created and signed, they must be filed with the local trade register. The business register examines the documents to determine whether they comply with national laws and regulations and to ensure that the proposed shareholders and directors are free from registered restrictions. Company registration usually takes between three and 14 days, depending on the country.