How to Set Up a Franchise Internationally โ Legal and Tax Structure (2026)
International franchising requires a Master Franchise Agreement (territory rights), a local entity in each market, and an IP holding company that owns the franchise system and receives royalties.

International franchising requires a Master Franchise Agreement (territory rights), a local entity in each market, and an IP holding company that owns the franchise system and receives royalties. Royalty withholding taxes vary by market (UK-US: 0%, EU-emerging: up to 20%). Structure: IP HoldCo (Ireland, Netherlands, or Cyprus) โ Master Franchise Agreement โ local operating entities. This article covers the legal documentation, royalty pricing (transfer pricing), and tax structure.
Need help choosing the right jurisdiction?
Use our free Country Picker tool or get a personalised consultation.
This content is educational and does not constitute legal or tax advice. Always consult a qualified professional for your specific situation. Data last verified March 2026.