A founder may live in Germany while the operating business remains in Ukraine. A holding company may sit in a third jurisdiction. Teams, bank accounts, customers and capital may be distributed across several countries.
LEXONYX reconstructs the actual business model, identifies the dependencies between jurisdictions and connects the relevant legal, tax, banking and governance workstreams into one coherent cross-border architecture.
The founder, business or capital acquires a German nexus.
A German business or investor acquires a Ukrainian operating or investment perimeter.
Review founder residence, company management, CFC/PE interfaces, owner payments, banking and governance before the facts change.
Reconstruct when residence changed, where management decisions were made, what payments occurred and whether governance matches reality.
Define the function of any German entity, allocation of people and functions, TP, VAT, PE, payroll, banking and capital flows.
Structure ownership, Ukrainian operations, JV or acquisition, financing, governance and the required local workstreams.
A dividend, business sale, loan repayment or investment may require tax analysis, FX execution and a coherent Source of Funds / Source of Wealth file.
Germany and Ukraine may be the anchor jurisdictions while ownership, banking, customers, financing or a holding layer sit elsewhere. The review begins with business reality, not with selecting a jurisdiction.
Who owns the companies and assets, who controls material decisions, and how the founder, holding and operating entities are connected.
Founder residence, company residence, CFC exposure, distributions and related reporting interfaces.
Where management is exercised, where people work, who negotiates and contracts, and which PE or payroll questions follow.
Domestic rules, treaty access, withholding tax, beneficial ownership and transfer-pricing interfaces affecting cross-border payments.
Who actually makes decisions, how authority is documented, and whether the evidence supports the real operating model.
UBO, business model, transaction flows, KYC/KYB, Source of Funds / Source of Wealth and explainability under external review.
Reconstruct the Current State: ownership, entities, functions, management, flows and evidence.
Define the Target State and realistic structural alternatives.
Separate jurisdiction-specific questions and identify the specialist workstreams required.
Integrate confirmed conclusions into one sequenced implementation roadmap.
Track factual changes that can alter residence, management, PE, CFC, banking or regulatory exposure.
A bounded diagnostic when the active structural issues first need to be identified.
Open format →For multi-entity structures where residence, CFC/PE, flows, governance and banking must be reviewed as one system.
Open format →For a defined relocation, restructuring, transaction, investment or implementation task after the architecture is established.
Open format →For operating structures that require continuing coordination as facts, banks and jurisdictions change.
Open format →Within the applicable professional scope, LEXONYX handles Ukrainian-law work, cross-border factual architecture, ownership and control mapping, governance architecture, banking readiness, SoF/SoW reconstruction, evidence architecture and coordination.
Where the matter requires a conclusion under German tax, corporate, employment, social-security, regulatory or other German law, the relevant conclusion is provided or confirmed by an appropriately qualified German professional.
Where the structure includes Cyprus, Poland, the Netherlands, the UK, the UAE, Switzerland or another jurisdiction, jurisdiction-specific conclusions are provided or confirmed by appropriately qualified local professionals where required.
Ukrainian company status, German management nexus, treaty residence, PE, CFC, payments, FX, banking and evidence.
Read GU-01 →Ukrainian taxation, treaty limits, German dividend taxation, foreign-tax credit, NBU execution and bank evidence.
Read GU-02 →How to split functions, management, customers, people, risks, intercompany flows, VAT, transfer pricing, PE and IP.
Read GU-03 →The broader relocation map across residence, ownership, management, PE, CFC, payments, banking and governance.
Read FM-01 →Where actual management is exercised and when German corporate-tax nexus may arise.
Read FM-02 →When working, management, sales or contracting functions from Germany may create PE questions.
Read FM-03 →The statutory sequence from German taxpayer nexus and the foreign-company gate through control, income and low taxation.
Read FM-04 →Not necessarily. The first task is to establish what changed in residence, management, functions, payments, banking and governance. Structural changes follow only if the facts justify them.
No. A German company should perform a defined function in the Target State. Its necessity depends on the operating model rather than the founder's address alone.
Yes, where it continues to perform a genuine and supportable role. The review focuses on how management, functions, risks, payments and governance are allocated after the facts change.
Those entities remain part of the cross-border analysis. Germany and Ukraine may be the anchor jurisdictions while third countries are assessed according to their actual function and the applicable legal, tax, treaty, substance and banking framework.
LEXONYX handles cross-border factual and structural architecture within its professional perimeter. German legal, tax and other regulated conclusions are provided or confirmed by appropriately qualified professionals in Germany where required.
Where Germany and Ukraine are both material to ownership, management, operations or capital, the first step is usually to see the structure as a whole.