International Tax Advisory · Munich

Cross-border expansion
deserves a tax structure
built before you move.

German manufacturers entering Eastern Europe or the US face permanent establishment risks, transfer pricing exposure, and treaty complications that surface years after the entity is already set up. The cost of fixing a poor structure is almost always higher than the cost of getting it right from the start.

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The problem

When a manufacturing company crosses a border, it does not just open a subsidiary — it creates a network of tax obligations that most production-side founders have never encountered. Permanent establishment exposure can arise from a single sales representative. Transfer pricing rules require that intercompany transactions be documented and priced at arm's length, from day one. Miss that window and you are not facing a fine — you are facing a restatement.

Eastern European jurisdictions move fast. Poland, Czech Republic, and Romania each run different corporate regimes, and all three have significantly tightened their rules on hybrid entities and interest deductions over the past five years. A structure that worked for a competitor in 2018 may carry material risk in 2024. The advice you received at the point of entry shapes every subsequent filing.

US expansion adds another layer: state-level nexus, the branch profits tax for German GmbHs, and the interaction between the US-Germany double tax treaty and BEAT rules. These are not edge cases — they are the predictable consequences of an unstructured entry into the US market. The manufacturers who avoid them plan the structure before the first sales call.

About

Elena Richter has spent 16 years working at the intersection of German manufacturing and international tax. Twelve of those years were at KPMG in Munich, advising large industrials on cross-border structuring. Since 2020, she has worked independently — taking on fewer clients and doing the work at closer range.

Her practice is built around one corridor: German mid-market manufacturers, €10–80M revenue, expanding east or west for the first time.

Full background →
16
Years of international tax practice
12
Years at KPMG Munich
2
Expansion corridors: Eastern Europe + US
How the work is structured
01
Assessment
A structured analysis of your current footprint, planned expansion, and the specific tax risks that follow. No generic framework — the output is specific to your entity type, target country, and transaction flows.
02
Structuring
Designing the right legal and tax structure before you execute. Holding company analysis, treaty selection, transfer pricing policy, and permanent establishment planning — resolved before the entities are formed.
03
Implementation
Working alongside your lawyers, accountants, and management to put the structure in place correctly. Documentation, intercompany agreements, and coordination with local advisors in the target country.
04
Ongoing advisory
Tax law in Eastern Europe and the US changes. The structure you built in year one needs to be maintained and adjusted as your business scales. Retainer relationships available for established clients.

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Most structuring problems are easier to prevent than to fix.

If you are planning an expansion in the next 12 months — or recently entered a new market and have questions about your current structure — get in touch.

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