Owning Nothing, Controlling Everything: The Lanzo d’Intelvi IP Blueprint

In today’s world, companies trade in code, brands, and algorithms rather than factories. Ownership is no longer the foundation of wealth — control is.

The founders who thrive are not those who own everything in one place, but those who design separation: between what they do, what they own, and what they show.

I explored this idea in my earlier essay, Milan to Lugano: The Hidden Corridor Where Lanzo d’Intelvi Redefines Business, describing how this quiet Italian town bridges the European Union’s legal order with Switzerland’s financial precision. Lanzo is more than scenic—it is structural. It is where ideas reside safely inside the EU, royalties flow across borders, and value stays protected yet accessible.

The Philosophy: Separate What You Own from What You Operate

In another piece, A Contract Does What Accounting Can’t, I argued that structure is the true art of modern finance. Contracts, not spreadsheets, determine where money sleeps and how it moves.

That logic extends here. The most resilient entrepreneurs separate their operating entities from their ownership vehicles.

The operating company runs the business, hires, and takes the risks.

The holding company owns the brand, software, and intellectual property.

Between them stands a legal firewall , a line that decides who survives a crisis. Lanzo d’Intelvi, with its modest costs and access to both EU and Swiss systems, offers fertile ground for that separation to grow.

The Blueprint: Three Jurisdictions, One Design

Lanzo SRL: The IP Owner

At the base sits the Lanzo SRL, an Italian limited-liability company under the Civil Code (Articles 2462 et seq.).

This is the vault that holds the group’s intangible assets — trademarks, patents, software, and creative know-how.

Because Italy belongs to the European Union Intellectual Property Office (EUIPO), one EU trademark protects a brand across 27 countries under Regulation (EU) 2017/1001. Combined with Italy’s 100+ double-taxation treaties (TUIR, Presidential Decree 917/1986, Article 23), royalties can circulate across borders with minimal friction.

Lanzo’s average real-estate cost of about €2,000 per sqm makes it easy to establish a genuine base — an office or residence that satisfies the economic-substance standards of OECD BEPS Action 5.

The SRL may also access Italy’s Patent Box Regime (Decree Law 146/2021, converted by Law 215/2021) granting a 110 % super-deduction for R&D related to qualifying intangibles, as well as the R&D Tax Credit (Law 160/2019, Article 1, §198 et seq.). Together they lower the effective tax on innovation to nearly half the statutory rate.

Dubai Free Zone Company: The Operational Core

The Dubai Free Zone company becomes the commercial heart of the structure. Formed under Federal Decree-Law No. 32 of 2021 and governed by the UAE Corporate Tax Law No. 47 of 2022, it handles contracts, marketing, and client operations.

It licenses the IP from the Lanzo SRL and pays arm’s-length royalties deductible under Article 28(1) of the tax law.

Because the UAE has over 140 tax treaties, including one with Italy, these payments often face no withholding.

If the Free Zone company earns mainly foreign-source income, it can qualify for a 0 % rate on that income under Ministerial Decision 139 of 2023. The result: real operations, global reach, minimal leakage — and full legal compliance through proper board meetings and economic-substance filings.

Swiss GmbH: The Credibility Hub

The third pillar is the Swiss GmbH, incorporated under Articles 772 et seq. of the Swiss Code of Obligations.

It serves as the client-facing entity, billing in CHF or EUR and providing Swiss banking reliability.

It pays two streams outward: service fees to the Dubai operator and royalties to the Lanzo SRL. Both are deductible under Article 58 of the Swiss Federal Tax Act, and treaties with Italy (1976, amended 2015) and the UAE (2012) minimize withholding.

With corporate rates in Canton Ticino around 11–15 %, Switzerland offers reputational weight without excessive taxation.

A small office in Lugano or Chiasso keeps the three jurisdictions physically close — Swiss contracts, Italian IP, Emirati operations — forming a coherent European-Emirati-Swiss bridge.

Why Lanzo Works

Lanzo’s strength goes beyond geography.

Legal Clarity: Italy’s civil law and EU directives on company and IP enforcement (Directives 2017/1132 and 2004/48/EC) make rights predictable and enforceable.

Cost Efficiency: Incorporation and yearly maintenance stay below €3,000, far lower than Milan or Zurich.

Strategic Access: Within 30 minutes of Lugano and Lake Como, 45 minutes from Malpensa Airport.

Lifestyle and Substance: A founder can live where decisions are made, fulfilling BEPS Action 5 substance standards while enjoying Alpine calm.

Lanzo’s combination of EU protection and Swiss proximity transforms it from a village into an intellectual-property citadel — small in scale, large in leverage.

Control Without Exposure

Ownership exposes; control protects.

By holding the Lanzo SRL through a UAE or Swiss foundation, licensing it to the Dubai FZ, and connecting it to a Swiss GmbH, a founder achieves functional separation. The person remains invisible yet indispensable, commanding the flow without carrying the risk.

As I wrote in A Vehicle for Wealth, Succession and Asset Protection, this is the essence of asset architecture: protecting through design, not secrecy.

Designing Silence

“Own nothing, control everything” is not about concealment, it is about intentional structure.

A strong design separates risk from reward, ownership from control, and exposure from power.

Sometimes, the smartest headquarters isn’t in a skyscraper; it’s in a mountain town overlooking two worlds, where a square meter still costs €2,000 and the law still rewards those who plan.

Lanzo d’Intelvi is not just a location. It is a statement:

My assets are silent, but my structure speaks.