IP Advisory
IP Migration
Moving existing intellectual property into Cyprus with valuation and assignment support.
What we do
We move existing intellectual property into a Cyprus company: valuation coordinated, assignment or contribution documented, filings made, and the pricing supported. And before any of it, we check whether moving the asset is the right route at all.
It often is not. Where the company holding the asset can move instead, redomiciliation brings the asset with it, so nothing changes hands and the asset's expenditure history stays with the same entity. A transfer is the right answer sometimes rather than by default, and working out which applies is the first thing we do.
What you get
- The two routes compared on your facts: transfer the asset into a Cyprus company, or move the company itself by redomiciliation
- Nexus modelling of where the transfer lands you, and of the trajectory under a stated development plan
- Independent valuation coordinated for the asset being transferred
- Assignment or transfer documentation, including any founder and contractor assignments still outstanding
- Contribution in kind against shares where that is the route, with the resolutions and Registrar filings
- Transfer pricing documentation supporting the consideration and any ongoing licence
- Development contracting structured so the spending that follows is qualifying expenditure
- Governance establishing that the asset is directed and exploited from Cyprus
How it works
A transfer produces no nexus. The acquisition cost enters overall expenditure and leaves the qualifying side untouched, so the receiving company starts with a low fraction. The uplift, capped at 30 percent of qualifying expenditure and limited by the non-qualifying amount, softens that without removing it.
So the plan matters more than the transaction. The fraction improves only as the Cyprus company funds further qualifying development, and because the measure is cumulative it improves gradually. We show the trajectory over the following years under your actual hiring intentions.
Whether the transfer triggers a charge in the country the asset is leaving is a question for your advisers there. We work the Cyprus side and coordinate with them, because that answer is sometimes large enough to decide the route.
Working with us
Four steps, and the first one is a conversation
A call
What the asset is, which entity holds it today, and who has been funding the development. No charge for it.
A proposal in writing
Fixed fees, not estimates, for the route the facts point to.
You accept
Engagement letter signed, then onboarding. Neither takes long.
The asset is in Cyprus, with the plan that follows it
Valuation, documentation and filings complete, and the development contracting arranged so the fraction starts building from the first month.
Common questions
Is it better to move the asset or move the company?
Moving the company is usually better where it is possible. Nothing changes hands, so on the Cyprus side there is no valuation, no consideration to support and no acquisition cost sitting in overall expenditure, and the asset's expenditure history stays with the same entity. Whether the origin jurisdiction charges the company on its way out is a question for your advisers there, and it is sometimes what decides the route.
What does the transfer do to our effective rate?
In the first years, more than most people expect. The purchase price counts against the fraction rather than for it, so the rate starts well above the 3 percent figure and comes down as the Cyprus company funds its own development. We model that curve before the transfer, not after.
Who values the asset?
An independent valuer, and that independence is the point. A related party transfer priced by the parties themselves is the arrangement most likely to be revisited later. We instruct the valuer, assemble what they need and carry the result into the corporate documents and the filings.
Will the country we are leaving charge us on the way out?
Some do, and where the answer is yes it can outweigh the Cyprus benefit for several years, so it is worth establishing before the transaction is designed. That answer comes from your advisers in that jurisdiction. We tell you what the Cyprus side is worth so the two can be weighed against each other.
What follows
Once the asset is here, the position is an annual one. Intellectual property regime work tracks qualifying and overall expenditure per asset as the year runs and computes the fraction in the return, and accounting and tax compliance carries the accounts and the audit coordination around it.
| Effect on nexus | Acquisition cost enters overall expenditure without improving the numerator |
|---|---|
| Uplift relief | Up to 30 percent of qualifying expenditure, capped at non-qualifying expenditure |
| Required at transfer | Independent valuation, assignment documentation, transfer pricing support |
| Alternative to consider first | Redomiciling the company, which avoids a disposal entirely |
| How the fraction recovers | Cumulatively, as the Cyprus entity funds further qualifying development |
| Exit jurisdiction risk | Possible exit charge or deemed disposal on the outbound transfer |
Also in IP Advisory
- Cyprus IP Box StructuringQualification analysis, nexus modelling and the deduction position under BEPS Action 5.
- IP Holding CompanyOwnership, licensing and assignment of intellectual property through a Cyprus entity.
- Transfer PricingIntercompany pricing, local file preparation and valuation coordination.
Find out whether Cyprus fits your plans
It starts with three questions: where your revenue comes from, what you own, and where you are tax resident. From there, the conversation is about what you are building and where you want to take it. After the call, you receive a written proposal covering the recommended structure, the implementation roadmap, and a fixed fee quote.