About
Sixteen years. One specific problem.
Elena Richter trained in tax at KPMG Munich, where she spent twelve years advising large German industrials — automotive suppliers, machinery manufacturers, chemical companies — on the tax implications of their international operations. She worked on restructurings, acquisition structuring, and transfer pricing disputes. She was part of the team. She knew how the machine worked.
What she noticed, consistently, was that the mid-market fell through the gap. Family-owned manufacturers in the €10–80M revenue range were making expansion decisions — setting up subsidiaries in Poland, entering the US through a distribution agreement, acquiring a small Czech supplier — with advice that was either too generic or arrived too late. The entry structure was an afterthought. The transfer pricing documentation came two years in, when the local authority was already asking questions.
In 2020, she left KPMG to work independently. Not to build a firm, and not to take on a broad client base. The practice is deliberately narrow: German manufacturers, family-owned or close to it, preparing for or recently executing a cross-border expansion into Eastern Europe or the United States.
The narrowness is the point. International tax in this corridor — the specific treaties, the specific risks, the specific decisions that arise when a Bavarian Mittelstand company crosses into Poland or opens a US sales subsidiary — is not something you can replicate with a generalist approach. It requires knowing the terrain well enough to see the problems before your client does.
"Tax structuring is not a compliance exercise. It is a set of decisions that either supports or constrains how your business can grow. Once you have incorporated a foreign entity, you have already made several of those decisions — the question is whether you made them deliberately or by default."
Elena approaches each mandate by mapping the full consequence chain before recommending any structure. That means understanding not just the tax position at formation, but what the structure implies for repatriation, for future acquisitions, for exit. A structure optimised for year-one entry tax costs can create serious problems for a founder trying to sell the business in year eight.
She works closely with her clients' other advisors — lawyers, accountants, management consultants — and coordinates with local counsel in the target countries. The structuring work is hers. The local implementation requires people who know those jurisdictions at ground level.
She does not take retainer clients who have already made irreversible structural decisions without expert input and are looking for someone to make it work retroactively. She takes clients early — ideally before the entity has been formed, certainly before the first intercompany transaction.
International Tax Practice
Senior Manager
Munich-based
€10–80M revenue
(PL, CZ, RO, SK, HU)
(all states, federal)
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