What makes ai & deep-tech startups different from an ordinary filing?
Where research and development is performed, funded and owned determines which country is entitled to the profit from the resulting intangible — and that is decided by conduct long before any exit. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
Who owns our IP if the developers are overseas?
Legal ownership is whatever the contracts say. Tax entitlement to the profit is a separate question, and it looks at conduct. A tax authority asks where the development work was actually performed, who bore the cost and the risk of it, and who made the decisions about what to build. If those answers point at one country while registered ownership sits in another, the paperwork is not the end of the matter. The fix is almost always cheap while the company is small — assignments signed, funding recorded, decisions minuted — and expensive once there is real value attached to the intangible.
Can we claim research incentives if we develop abroad?
That depends on the incentive, and its conditions are usually about where the work is done and who bears the cost rather than where the claimant is registered. A programme may require the activity to be performed in the country, or permit some proportion abroad, or require the claimant to own the results. Claiming in one country while the development sits in another is the combination most likely to be examined, and the examination is evidential: contracts, timesheets, who directed the work, who paid for it. Building that record as you go costs little. Reconstructing it during an enquiry is a different exercise.
Does a founder moving country change where our IP is taxed?
It can, because the founder is often the person whose decisions the analysis follows. Where the people who direct development, approve the roadmap and carry the commercial risk move, the country entitled to the profit from what they produce may move with them. Two other things can move at the same time: the company's own residence, if management is exercised from the new country, and the founder's personal position on shares they hold. None of it is automatic, and all of it turns on facts that can be arranged deliberately if the question is asked before the move rather than after.
What do investors ask about our cross-border structure?
In diligence the recurring questions are whether the company actually owns what it says it owns, whether the people who built it assigned their rights, and whether the way profit is allocated between group entities matches where the work happens. What tends to hold a round up is not a wrong answer but an unanswerable one: contracts missing, contributors who never signed, intercompany arrangements never written down. Preparing that file before the round turns the question into a document exchange. Preparing it during the round turns it into a negotiation about price, or an indemnity you carry afterwards.
Do we need transfer pricing documents before we have revenue?
Formal documentation obligations usually attach to size or to particular transactions, so a pre-revenue company may have none. The underlying requirement is different. Dealings between connected entities are expected to be on the terms independent parties would have agreed, and that applies from the first intercompany transaction, not from the first sale. A development company charging its parent, or a parent funding a subsidiary's research, is already making an allocation. Recording the basis at the time is straightforward. Establishing years later what a contract between two entities you control was meant to say is not.
Can we move our IP into a holding company later?
Moving an intangible between connected companies is a transaction both countries will look at, and the price is expected to reflect what the asset is worth at the time of the move. That is why timing matters so much: a transfer made before the technology has demonstrated value raises a far smaller question than one made after a product is selling. It is also why the conduct record matters, because if development continues in the country the asset left, the entitlement question comes straight back. A move is possible. A move treated as an internal formality is what causes difficulty.
How many days can I spend in a country before I become tax resident?
It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.
How do I actually stop being taxed twice?
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
