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.
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 →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 →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 →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 →Analysis of international group architecture: allocation of functions, tax consequences, substance and impact on banking review.
Go to the structuring topic →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 →Control and management, source of funds, alignment of documentation and the link between the structure and regulatory logic.
Go to the banking readiness topic →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.
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.
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.
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.
Describe the situation — we will identify the key risks, management logic and possible restructuring scenarios.
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