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1. hello there ..

   I am wanting legal assistance and advice on setting up and establishing a fully compliant off shore structure to manage UK based IP royalty income for music artists.

   I would like to create a tax neutral vehicle that can commercially manage these royalties and redistribute discretionary bonuses to UK music artists, while remaining fully safeguarded from UK tax exposure — including protections from TOAA, GAAR, and related anti-avoidance legislation.

   I’m currently considering jurisdictions such as Cayman Islands, Gibraltar, or Anguilla due to their 0% tax frameworks and other favourable legal regimes.

   please note that I will be a non UK resident.

   I am looking for a complete legal set up and framework so that I can perform this type of business model ..

   I am aware I will be needing preparation of all necessary legal and commercial documents .. contracts and potential legal opinion letters so that I can use to perform this type of business ..

   I assume these may include some of the following ..

   IP assignment and licensing agreements,

   Royalty redirection contracts,

   Income redirection and discretionary bonus agreements,

   Priority assignment letters,

   Internal company structuring memos,

   Legal opinions supporting HMRC protection.

   I have already developed a number of core documents covering this structure and would also like to know whether your firm can review, amend, and validate these as well if needed ..

   in regards to this IP royalty income stream that I will be handling .. I need to make sure that this income is completely free from UK hmrc tax rates please .. and even once the UK artist receives my companies off shore discretionary bonus payments, this must also be free from UK hmrc tax rates please ..

   again please note that I’ll be a fully non UK resident while performing this business model ..

   I look forward to hearing from you ..

   many thanks ..

   Spiros ..

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