A process, not a product.

Before any structure can be proposed, the existing situation needs to be understood precisely. This means reviewing your current German entity structure, your ownership chain, your planned expansion (country, model, timeline), and the nature of the transactions that will cross the border.

The output is a risk and opportunity map. Not a slide deck with generic frameworks — a specific written analysis of what your entry will trigger, what the treaty position is, and where the structural options actually lie. This becomes the basis for phase two.

• Review of existing German holding and operating structure
• Analysis of target country tax regime and applicable treaty
• Identification of permanent establishment risks
• Transfer pricing implications of planned intercompany flows
• Written assessment memo, typically 15–25 pages

This is the core of the engagement. Based on the assessment, two or three structural options are developed in full — entity type, holding structure, treaty position, transfer pricing approach, repatriation mechanism. Each option is modelled against your specific facts: your revenue profile, your ownership goals, your five-year plan.

The recommendation is not the cheapest option, and it is not the most defensible option. It is the one that is best for your business over the relevant horizon, explained in terms you can take into a board meeting with your siblings.

• 2–3 structural scenarios developed in full
• Treaty analysis and entity type selection
• Transfer pricing policy design (method, documentation approach)
• Repatriation and dividend withholding analysis
• Future exit and acquisition optionality
• Final structuring recommendation with written rationale

A good structure on paper is worth nothing if the implementation does not match the design. This phase involves working alongside your legal counsel, corporate secretarial provider, and local accountants to ensure the entities are formed correctly, the intercompany agreements reflect the transfer pricing policy, and the substance requirements in the foreign jurisdiction are actually met.

Substance is the most common failure point. A subsidiary that looks like a holding company on paper but has no real presence in Poland does not withstand scrutiny. Implementation means getting that right — not delegating it and hoping.

• Coordination with German lawyers and local counsel
• Review of articles of association and shareholder agreements
• Intercompany agreement review and transfer pricing documentation
• Substance requirements — directors, offices, decision-making
• Filing and registration coordination

Tax law in Eastern Europe has changed substantially over the past five years. The US continues to refine its approach to GILTI, BEAT, and Pillar Two. A structure that was optimal at formation needs to be reviewed when the law changes and when your business changes.

Ongoing retainer clients receive a structured annual review of their international structure against any legislative changes in the relevant jurisdictions, plus access for ad hoc questions on transactions and decisions that arise during the year. Retainer relationships are offered only to clients who have completed the initial structuring engagement.

• Annual structure review against legislative changes
• Transfer pricing documentation update
• Ad hoc advisory on transactions and new expansion decisions
• Coordination with local compliance providers