IpCo (Intellectual Property Company)
A subsidiary dedicated to holding and exploiting a group’s intellectual property — trademarks, software, patents, databases — and licensing those assets to the operating entities. It is typically located in a jurisdiction offering favourable IP income taxation.
In practice
Sited in Ireland at 6.25%, Luxembourg, or France via the IP Box at 10%, an IpCo concentrates the group’s intangible value. For a SaaS publisher generating 2 million euros in annual licences, housing the source code in an Irish IpCo can reduce effective tax from 25% to 6.25%. Economic substance — real staff, decisions taken on site — is mandatory to avoid the risk of the structure being recharacterised as artificial by tax authorities.