IP & Trademarks

Move Your IP & Trademarks into a Tax-Efficient UAE Structure

Turn Your Intellectual Property Into a Strategic Business Asset

Your brand, trademarks, patents, software and know-how can be some of the most valuable assets your business owns.
But where those assets are held can also affect how your business is structured and how income generated from them is taxed.

At Evolve Tax, we help UK businesses assess whether their intellectual property can be moved into a properly structured UAE holding company, with the appropriate licensing arrangements and genuine commercial substance behind the structure.
The objective is to create a tax-efficient, transparent and properly documented IP structure while maintaining the appropriate UK and UAE compliance.

Why Does IP Ownership Matter?

For many businesses, the most valuable part of the company isn't its physical equipment or premises. It is the intellectual property behind the business.

This can include:

If your business owns valuable IP, where that IP sits within your corporate structure deserves careful consideration.
A properly designed structure can separate the ownership of intellectual property from the day-to-day trading activities of the business.

What Is an IP Holding Company?

An IP holding company is an entity established to own and manage intellectual property assets.
For suitable UK businesses, a UAE company can potentially be used as the IP holding entity.
The trading business can then use the intellectual property under an appropriate licensing arrangement.

The exact structure depends on the nature of the IP, the businesses involved and the commercial circumstances.
The IP must genuinely sit within the structure and the arrangement must have appropriate substance behind it.

How Can an IP Structure Work?

The process starts by understanding what intellectual property your business actually owns.
We then assess how that IP is currently held and how it contributes to your company's revenue and value.
Where appropriate, the IP can be transferred to a UAE holding company and licensed back to the trading business.

The aim is to ensure that the IP structure reflects a genuine commercial arrangement rather than simply moving an asset on paper.

IP Valuation

Before transferring valuable intellectual property, it is important to establish an appropriate valuation.
Depending on the asset, this could involve reviewing:

A clean and appropriately supported valuation provides the foundation for the transfer.
Our IP restructuring process includes IP valuation and a properly documented, arm's-length transfer.

Transfer Your IP Into the UAE

Once the IP has been appropriately assessed and valued, the next stage is the transfer.
This needs to be properly documented and structured as a genuine commercial transaction.

We help coordinate the relevant process, including:

The objective is to create a clear chain of ownership and ensure that the structure can be properly evidenced.

Licensing Your IP Back to Your Business

Once the UAE holding company owns the relevant IP, the trading business can potentially use that IP through a licensing arrangement.
This can involve royalty or licensing payments from the trading company to the IP holding company.

The licensing arrangements need to be appropriately documented and structured.
They should reflect genuine commercial terms and satisfy the relevant HMRC requirements.

Genuine Substance Behind the IP

Moving IP to a UAE company is not simply an administrative exercise.
The structure needs to be genuine.
A UAE holding company should have appropriate substance behind its role within the wider business structure.

This is an important part of ensuring the arrangement is properly established and maintained.
Our approach therefore focuses on:

The objective is to build a structure that is supported by real commercial substance rather than simply creating an offshore entity on paper.

Trademark Registration & Protection

Your intellectual property strategy isn't only about tax.
Your trademarks and brand assets also need to be properly protected.

As part of the wider structure, we can help coordinate:

This allows the commercial protection of your brand to be considered alongside the wider corporate structure.

Who Could Benefit From an IP Holding Structure?

An IP and trademark restructuring review may be relevant to businesses that own valuable:

When Should You Review Your IP Structure?

IP Migration & Business Restructuring

In these circumstances, reviewing the ownership and licensing of your intellectual property alongside the wider group structure can be important.
Rather than treating IP as a separate issue, we look at how it fits into your overall corporate structure.