The money mechanics
Outbound royalties from the Netherlands meet 0% withholding under domestic law (the conditional levy targets only listed low-tax destinations), and inbound royalties arrive with source-country withholding capped by the treaty library — the India and US chapters being the classics: the MFN story and the US page. Where the licensed technology is your own qualifying development, the profit sizes into the innovation box: the 9%.
The pricing that holds
Intra-group licensing lives on arm’s-length terms: a rate a third party would pay, benchmarked and documented, with the substance behind the licensor real — people who actually manage the IP, decisions minuted here: the standard. Paper structures parking IP where nobody works stopped surviving audits a decade ago; genuine development-and-management here is exactly what the regime rewards.
The contracts
Scope (field, territory, exclusivity), the royalty base defined so both bookkeepers compute the same number, audit rights, improvement ownership, and termination that returns rights cleanly. In the group chart, IP sits at the holding or a dedicated IP BV, licensed down to operators — the pattern across this cluster from studios to biotech: the studio version, the programme version, inside the skeleton.