The royalty conduit structures we advise, consist of using licensed Dutch fiduciary services providers to own Dutch royalty conduit companies. This business model differs markedly from the traditional royalty conduit set-up where clients own the Dutch conduit entities themselves. It should be noted that the tax definition of ”royalties” is much wider than the legal definition thereof. The Dutch legal entities involved will be incorporated by and will remain in the possession of a licensed Dutch fiduciary services provider. As such they will be third parties, escaping all the tax provisions applicable to related entities (transfer pricing rules; documentation rules; the special Dutch substance rules for Dutch conduit companies; the special Dutch capital requirements for Dutch conduit companies etc.). The entities will be used by our clients for royalty conduit purposes, which might be a cross-border leasing structure or a cross-border licensing structure. Reinvoicing companies are getting increasingly popular, e.g. in the areas of cross-border technical services and cross-border consultancy fees. The fiduciary services provider charges a fee (gross margin) for making his legal entities available to clients for their royalty flows of between 2 and 6%, depending on the size of the royalty flows they collect, and the business risks and expenses involved (which vary from case to case). All day-to-day expenses incurred to run the Dutch company are for their account, including accounting fees, legal fees, tax consultancy fees, taxes to be paid, etc. with the exception of legal fees and IT expenses should the Dutch conduit have its own presence on the internet. We have the connections with the Dutch fiduciary servics providers that offer this business model and our fee for such a project may well be a success fee (i.e. part of the gross margin realised by the conduit entity).