The client had a number of questions about the procedure of software licensing and sublicensing and the tax aspect of such relationships.
In the interest of the client, we provided advice on:
- determining whether or not the payment under the draft license agreement is royalty;
- determining opportunities to prevent the recognition of payment under the draft license agreement as a royalty and, accordingly, its recognition as a means of payment for the supply of software products;
- determining the possible risks of not recognizing the sub-licensor as the "beneficial owner of the income".
This case study is a successful example of our business-oriented approach to client projects and goals and finding solutions focused on profit maximization.