Alright, but you will not be doing any work in your home country and in Portugal and only in Luxembourg?I am the owner of the IP personally (me and my business partner). The company in my home country has only a licensing agreement. Also, I can demonstrate the app was created years before I created my home country company if necessary.
Why do you say that you might not be able to deduct royalties expenses? They are expenses that a company can deduct. In my home country (western Europe) tax man let you deduct it.
Well I don't know about the royalty expenses, I would get that double checked with a professional.