Operating layer
Keep contracts, staffing and operating risks in the appropriate entity, supported by real separation and sound agreements.
Wealth Structuring & Asset Protection
Map assets, ownership and business risks, with a plan for professional review and implementation.
We map how your business, ownership interests, assets and banking arrangements connect. With your advisers, we develop a target structure that clearly separates operating and asset-holding responsibilities. The implementation plan identifies the reviews, responsibilities and documents required at each step.
What we focus on
- An overview of entities, ownership, assets and liabilities
- Review of operating and asset-holding responsibilities with your advisers
- Comparison of possible company layers and their ongoing obligations
- Documentation of accounts, ownership and responsibilities
- Alignment of the target structure with your business and personal plans
How we work
Our role is analytical and strategic. We prepare the structure, the comparisons and the decision paths — and coordinate implementation with your existing advisers or with qualified licensed partners where regulated services are required.
Important: We are not a broker-dealer, investment adviser, or law firm, and we do not provide financial, legal, or tax advice.
Separate responsibilities. Allocate assets.
Holding layer
A suitable holding or reviewed US LLC may hold assets separately. Charging-order rules concern specific personal creditor rights; they do not create universal enforcement immunity.
Liquidity layer
Review banking relationships against access, counterparty risk and cash needs. Georgian accounts may be an additional option outside the EU and US. Disclosure and information exchange remain applicable.
Transfers must be lawful, timely and commercially justified. Existing creditor rights, avoidance and insolvency rules require review before implementation.
From a German perspective.
Management & permanent establishment
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AOControlled foreign companies
Control, income type and actual taxation matter. The low-tax threshold is below 15% (as of 09/2026); EU/EEA substance rules require evidence.
Sections 7–13 AStGForeign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AOExit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStGRemaining German interests
German nationals meeting all relevant conditions may face extended limited taxation for up to 10 years after the departure year (as of 09/2026). Preferential taxation alone is insufficient.
Section 2 AStGTax treaties
Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty statusThis overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.