Germany–Ukraine DTT 2026: signed does not yet mean applicable
Treaty status, transition from the 1995 agreement, rates, PE, effective management, CFC, PPT and the structural logic for owners and groups.
Open Treaty Monitor →ANALYTICAL FORMAT
Analyses
Structural analyses of international models: the logic of building a group, tax consequences, substance, PE risk, VAT and banking readiness.
Analyses are architectural analytical maps. We analyse the allocation of functions, risks and assets, the alignment of tax logic, governance and banking expectations.
INTELLECTUAL FRAMEWORK
Five strategic axes of the Deep Dive series
Group Structure · PE · VAT · CFC & Residency · Banking. Read them as one interconnected system: a weakness in one axis can change the risk profile of the whole structure.
Founder in Germany: Dividend, Salary, Director's Fee or Management Fee?
How four legally different payment routes interact with German tax, Ukrainian tax, the current treaty, payroll, social security and evidence.
Read GU-04 →German GmbH + Ukrainian Operating Company
How to split functions, management, customer ownership, people, risks, service flows, VAT, transfer pricing, PE and IP between the German and Ukrainian companies.
Read GU-03 →Founder in Germany, Ukrainian Company Still Operating
How Ukrainian entity status, German management, treaty residence, PE, CFC, payments, FX rules and evidence reconnect after founder relocation.
Read the Germany–Ukraine analysis →Dividends from a Ukrainian Company to a Founder in Germany
Separate Ukrainian PIT and military levy, treaty ceilings, German taxation, foreign-tax credit, NBU execution and banking evidence.
Read the dividend analysis →Home office after founder relocation: when does PE risk arise?
A function-first analysis of working, managing, selling and contracting from a German home, including OECD 2025 guidance, German domestic nexus and treaty Article 5.
Read the home-office PE analysis →Founder moves to Germany: when can foreign companies trigger German CFC rules?
A current-law sequence through management location, §7 control, §8 income and low-tax tests, §13 investment income, attribution, evidence and filing.
Read the German CFC analysis →Foreign company managed from Germany: where is Geschäftsleitung?
A technical analysis of §10 AO, BFH case law, management from home, multiple management locations and the KSt, Gewerbesteuer and treaty consequences.
Read the management-location analysis →Founder moves, business stays: what actually changes?
A structural review of what can change when the owner relocates: personal and corporate residence, management, PE, CFC, banking, governance and evidence.
Read the founder mobility analysis →HoldCo / OpCo
When a holding company is a strategic centre — and when it becomes a source of risk.
Read →PE and remote teams
Where permanent-establishment exposure can arise in remote and digital operating models.
Read →VAT, OSS / IOSS and fixed establishment
How warehouses, supply chains and people footprint affect VAT architecture.
Read →Company structure and personal tax nexus
Why an international company structure does not by itself resolve personal residence or CFC exposure.
Read →Banking as an architecture stress test
How governance, source of funds and documentation are tested during onboarding.
Read →Recommended reading order: start with HoldCo / OpCo, then PE and VAT, followed by CFC & Residency and Banking Readiness.
HoldCo / OpCo / ServiceCo: aligning the group with real operating logic
Analysis of international group architecture: allocation of functions, tax consequences, substance and impact on banking review.
Go to the structuring topic →VAT architecture for e-commerce: OSS, IOSS and fixed establishment
When OSS is sufficient, and when local VAT registration obligations arise. The impact of warehouses, marketplace models and people footprint on the tax picture.
Go to the VAT topic →Banking readiness: preparing the structure for onboarding
Control and management, source of funds, alignment of documentation and the link between the structure and regulatory logic.
Go to the banking readiness topic →FAQ
Briefly, to the point
What are structural analyses?
Analyses are deep cases of international models: the logic of building a group, tax consequences, substance, PE risk, VAT and banking readiness. They show not universal schemes, but a way of thinking: how the elements of a model are connected and why a structure works or starts to diverge from reality.
Which topics are analysed?
Analyses include the alignment of HoldCo/OpCo/ServiceCo with the real operating model, VAT architecture for e-commerce with OSS, IOSS and fixed establishment, and preparing a structure for banking onboarding. Each case shows the logic of building the model and the typical points where the model most often requires review.
How does an analysis differ from a briefing?
A briefing is a short signal about a change in context. An analysis is a detailed case with the full logic of building a model and its consequences for tax, presence and the bank. Analyses provide depth of understanding of how a resilient structure is assembled, while briefings keep track of changes in the external environment.
Are the analyses applicable to my structure?
Analyses show patterns and logic applicable to many models, but they do not replace analysis of your specific structure. They help you understand how to think about your own architecture and which questions to ask. Assessing your model with its specific jurisdictions and flows is possible only through a personalised review.
NEXT STEP
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