Table of Contents Why I Took a Closer Look at Three EU Locations Malta as a Business Location: The Truth Behind the Tax Promises Ireland for International Companies: More Than Just Low Corporate Tax Netherlands as a Business Hub: Infrastructure vs. Tax Burden Direct Comparison: Taxes, Costs, and Operational Reality My Recommendation: Which Location Fits Which Type of Company The Most Common Pitfalls and How to Avoid Them Frequently Asked Questions Why I Took a Closer Look at Three EU Locations After five years working as a consultant for international business structures, I can guarantee you one thing: the choice of EU location will make or break your company’s success. I’ve guided dozens of clients through Malta, Ireland, and the Netherlands—and learned that the shiny economic development brochures only tell half the story. The EU freedom-of-establishment rules for businesses sound tempting: one location, access to all 27 markets. But reality? A tax advisor in Dublin who takes three weeks for a simple registration. A Maltese notary suddenly demanding extra compliance documents. Or a Dutch tax office that interprets your place of business differently than you do. What You’ll Learn in This Comparison I’ll show you the unfiltered truth about three of the most popular EU business locations. No marketing promises—genuine facts, hidden costs, and operational hurdles that others don’t tell you about. You’re about to find out: Which tax benefits actually exist (and which are just on paper) What it really costs to set up a company—including all side expenses How long administrative processes truly take (spoiler: longer than promised) Which hidden compliance traps are waiting for you Which location is best for which type of company My Methodology: Facts, Not Marketing All figures in this article come directly from official sources of the respective tax authorities and chambers of commerce (as of 2025). I spoke with local lawyers, tax consultants, and entrepreneurs operating in these countries for years. The result: an honest comparison that saves you time, money, and nerves. Ready for the truth? Let’s start with Malta—the presumed tax haven that comes with its own pitfalls. Malta as a Business Location 2025: Tax Benefits and Hidden Costs Malta sells itself as the Singapore of the Mediterranean—and indeed, the island tempts with its impressive tax rates. But after helping over 40 companies set up in Malta, I know: the reality is far more complex than the glossy brochures suggest. The Maltese Corporate Tax: 6/7 System Explained Malta’s famous 6/7 system (Imputation System) reduces the effective corporate tax rate from a nominal 35% to 5%—if you meet all requirements. Here are the facts: Type of Company Nominal Tax Rate Effective Tax Rate Conditions Trading Company 35% 5% Substance in Malta, real business activity Holding Company 35% 0-5% Participating Exemption possible IP Holding 35% 5% IP must be developed/managed in Malta Gaming License 35% 5% Malta Gaming Authority license The 6/7 system works through refunds: you first pay 35% corporate tax, but on dividend distribution, 30% is refunded. Effectively, you’re left with 5%—provided that the Malta Business Registry accepts your substance. What Substance in Malta Really Means This is where things get tricky. The Maltese authorities are scrutinizing more closely whether your company has real economic substance. From my experience, at a minimum you need: Local management: A Malta-resident director with real decision-making powers Physical presence: An actual office (not just a mailing address) Local staff: At least 1–2 full-time employees for operational activities Board meetings: Regular board sessions in Malta Bank account: A Maltese business account One client of mine, let’s call him Thomas, runs an IT consultancy. His Malta setup works because he personally spends four months a year in Valletta, employs a local operations manager, and channels all client projects through Malta. Total cost: Around €85,000 a year for staff and infrastructure. The Hidden Costs of Setting up in Malta The setup costs are just the beginning. Here’s a realistic cost breakdown for year one: Cost Item One-off Annual Remarks Company Formation €2,500 – Incl. notary and registration Tax Advisor – €8,000–15,000 Depending on complexity Audit – €5,000–12,000 Required from €46,587 turnover Office Costs €3,000 €12,000–24,000 Valletta/Sliema center Local Director – €25,000–45,000 Depends on qualifications Banking Setup €1,500 €2,400 Account maintenance and compliance Realistic total costs year 1: €55,000–100,000 Operational Challenges in Malta Malta is an island—you feel that every day. The logistics for physical products are more expensive and slower than on the mainland. Internet and telephony are reliable but not cheaper than in Germany. Office spaces in good locations are overpriced: A 100m² office in Valletta costs at least €2,000 per month. The work culture? More relaxed than in Germany, but also less punctual. Appointments are guidelines, not fixed deadlines. The tax office closes at 4:30 p.m., and on Fridays, not much happens after 3:00 p.m. Sounds relaxed, but can drive you crazy if you’re used to German efficiency. What does this mean for you? Malta is ideal for digital companies with high margins. If youre making at least €200,000 annual profit and can actually move operations to Malta, the tax savings are significant. For smaller businesses or pure holding structures, it quickly gets expensive. Ireland for International Companies: The Complete Guide 2025 Ireland has firmly established itself as the “Gateway to Europe”—for good reason. Apple, Google, and Facebook have their European headquarters here. But what works for tech giants doesn’t necessarily fit your business. After three years of intensive consultancy for Ireland, I know the pros and cons firsthand. Ireland’s Tax System: More than Just 12.5% Corporate Tax Ireland’s 12.5% corporate tax rate is competitive EU-wide, but it’s not the only factor. The Irish tax system is more nuanced than Malta’s, but also more transparent and predictable: Tax Type Rate Applicalbe Income Corporation Tax 12.5% Trading income (operating profits) Corporation Tax 25% Passive income (capital gains, rents) VAT 23% Standard rate Capital Gains Tax 33% Capital gains Withholding Tax 20% Dividends (reduced via double tax agreements) The key advantage: Ireland’s extensive double taxation treaty (DTT) network. It has agreements with over 70 countries, reducing or eliminating withholding taxes. That makes Ireland especially attractive for international holding structures. Substance Requirements: Less Strict than Malta Ireland takes a more pragmatic approach to substance. The Revenue Commissioners (tax authority) focus on real business activity, not just physical presence at all costs. My formula for Irish substance: Management and Control: Strategic decisions must be made in Ireland Qualified Personnel: At least one Ireland-resident director with real authority Local Operations: Administrative and operational activities onsite Business Premises: An actual office (not a mailbox) Books and Records: Bookkeeping and key documents kept in Ireland Example from practice: My client Sarah runs a digital marketing agency. She moved management to Dublin, employs three local staff, and runs client projects from there. Irish authorities accept this structure without issues. Her annual compliance costs: around €45,000. Setup and Ongoing Costs in Ireland Ireland is more transparent on costs, but not cheaper than Malta. Prices are on par with Western European standards: Cost Item One-off Annual Remarks Company Formation €1,200 – CRO Registration, constitution Professional Services – €12,000–25,000 Tax agent, accountant Audit (if required) – €8,000–20,000 Depends on company size Dublin Office €5,000 €24,000–48,000 City centre, 100m² Local Staff – €35,000–55,000 Per full-time employee Annual Return – €40 CRO filing fee Realistic total costs year 1: €75,000–145,000 R&D Tax Credits: Ireland’s Secret Weapon This is where Ireland truly shines: Research & Development Tax Credits can significantly reduce your tax bill. You get 25% of eligible R&D expenses as a tax credit—in addition to the normal cost deduction. That’s an effective support of 37.5% on your R&D costs. What counts as R&D? Software development (if systematic and innovative) Product development and improvement Process optimisation Employee costs for R&D activities External research services A tech startup I work with saves €60,000 per year via R&D Tax Credits—with €240,000 in eligible R&D spend. More than enough to cover Ireland’s higher cost base. The Operational Reality in Dublin Dublin feels like a real metropolis—unlike Valletta. The infrastructure is excellent: gigabit internet, an international airport with direct US connections, a reliable (though overloaded) public transit system. The working culture is professional and international. English as the official language makes dealings with authorities easier. The tax office is digitally advanced—returns can be filed online, and responses usually come in weeks, not months. The downside: Dublin is expensive. Office costs are higher than in Germany, qualified employees are scarce and costly. An experienced tax advisor runs €150–200 per hour. What does this mean for you? Ireland is perfect for tech businesses, innovative service providers, and holdings with international participation. The R&D tax benefits make it especially interesting for development-heavy companies. But you’ll need at least €300,000 annual profit to justify the higher costs. Netherlands as a Business Hub: Infrastructure vs. Tax Burden 2025 The Netherlands expertly markets itself as the Gateway to Europe. Amsterdam and Rotterdam offer world-class infrastructure, but the tax burden is higher than in Malta or Ireland. After two years of focused consultancy in the Netherlands, I can tell you: your success here is about much more than just the tax rate. The Dutch Tax System: Complex but Predictable The Netherlands bet on legal certainty rather than aggressive tax optimisation. The corporate income tax system is transparent, but not cheap: Profit Bracket Tax Rate 2025 Remarks 0 – €200,000 19% Reduced rate for SMEs Above €200,000 25.8% Standard rate Additional taxes and levies: VAT (BTW): 21% standard rate Withholding Tax: 15% on dividends (often reduced via DTTs) Capital gains: Taxed as ordinary business profits Local taxes: No additional regional corporate taxes Participation Exemption: The Dutch Trump Card This is where the Netherlands shines: Participation Exemption means profits from qualifying shareholdings are fully exempt from tax. Conditions: Minimum 5% share in participation The participation is not held as inventory No participation in low-tax jurisdictions (under 10% tax rate) This makes Dutch holdings extremely attractive. For example: My client Klaus holds stakes in German and French companies through his Amsterdam B.V. Dividends flow tax-free through the Dutch holding—only German and French withholding tax applies (reduced via DTTs). Substance Requirements: Stricter than Expected Dutch tax authorities scrutinise substance carefully—especially for holdings. Since the EU Anti Tax Avoidance Directive (ATAD), a mailbox structure no longer cuts it: Substance Criterion Minimum Requirement Recommendation Personnel 1 qualified person At least 0.5 FTE onsite Office Genuine business address Own or leased office space Decision Making Board meetings in NL Quarterly meetings with minutes Bank Account Dutch account All payments via Dutch account Setup and Operating Costs The Netherlands are transparent about fees and costs. Here are realistic figures for a B.V. (similar to a German GmbH): Cost Item One-off Annual Remarks B.V. Formation €1,500 – Notary, Chamber of Commerce registration Tax Advisory – €8,000–18,000 Ongoing compliance Bookkeeping – €6,000–12,000 Monthly accounting Amsterdam Office €3,000 €18,000–36,000 50m² central, shared office Local Manager – €40,000–65,000 0.5–1.0 FTE Banking €500 €1,200 Business account with ING/ABN Realistic total costs year 1: €75,000–130,000 The Innovation Box: Hidden Tax Bonus The Netherlands has an ace up its sleeve: the Innovation Box taxes profits from self-developed intellectual property (IP) at just 9%. What qualifies? Patents and patent-equivalent rights Software (if innovative and self-developed) Income from R&D activities License revenues from own IP A software company in my portfolio makes use of the Innovation Box for its SaaS platform. Instead of 25.8%, it pays just 9% tax on software license profits—a saving of over €100,000 per year. Operational Excellence: Why the Netherlands Works Amsterdam feels like Europe’s Silicon Valley. Infrastructure is world-class: Schiphol Airport (fourth largest cargo hub in Europe), Rotterdam port (largest European seaport), fibre-optic internet everywhere. Government digitalisation is exemplary—everything is done online, responses are prompt. The work culture is efficient and international. English is a common business language, even in public offices. Legal certainty is high, contracts are honoured, and courts are consistent and predictable. The workforce is highly qualified but expensive. An experienced tax manager costs €80,000–120,000 per year. Office costs in Amsterdam are tough: €400–600 per m² in the city centre. But you really do get global city quality for it. Double Irish Dutch Sandwich: Gone, but Alternatives Exist The famous Double Irish Dutch Sandwich structure ended in 2020. But the Netherlands remain attractive for international structures: Holding structures: Participation Exemption renders holdings tax neutral IP holdings: Innovation Box at 9% for self-developed IP Financing structures: Interest is tax-deductible Treaty-shopping: Vast DTT network reduces withholding tax What does this mean for you? The Netherlands are perfect for established businesses that value legal certainty and infrastructure over minimal tax rates. Holdings and IP-driven companies in particular benefit. But you’ll need at least €500,000 annual profit to make the high costs worthwhile. EU Business Location Comparison: Malta vs Ireland vs Netherlands 2025 After three intensive years consulting in all three countries, I can give you a clear verdict: there is no “best” location—only the best one for your specific situation. Here’s the unfiltered comparison of all key factors. Tax Burden: Direct Comparison Effective tax burden depends heavily on your business model. Here are the real rates for various types of companies: Type of Company Malta Ireland Netherlands Trading Company 5% (with 6/7 system) 12.5% 19–25.8% Holding Company 0–5% 12.5% (or 0% with exemption) 0% (Participation Exemption) IP/License Company 5% 12.5% (+ R&D credits) 9% (Innovation Box) Tech/Software 5% 12.5% (+ R&D credits) 9–25.8% (depending on IP share) Total Costs over the First Three Years Tax rates are only half the story. Here are realistic total costs for a medium-sized company with €500,000 annual profit: Cost Factor Malta (3 years) Ireland (3 years) Netherlands (3 years) Setup Costs €15,000 €20,000 €12,000 Operating Costs €240,000 €350,000 €320,000 Taxes (on 500k profit) €75,000 €187,500 €387,000 Total Costs €330,000 €557,500 €719,000 Calculation: €500,000 profit × 3 years, minus operating costs, plus actual tax burden Compliance Effort & Legal Certainty Here, the three countries differ considerably: Malta: High compliance effort, complex rules, but predictable if done right Ireland: Moderate effort, clear rules, extremely high legal certainty Netherlands: Moderate to high effort, but extremely high legal certainty Infrastructure and Business Environment Factor Malta Ireland Netherlands Internet speed Good (50–100 Mbps) Excellent (gigabit) Excellent (gigabit) Flight connections Limited Very good (global) Excellent (global) Talent pool Limited Good (tech hub) Excellent Office costs High for island standard Very high Extremely high Banking system Conservative, slow Modern, efficient Excellent Risk Factors: What Can Go Wrong From three years of consultancy, I know the common pitfalls in every country: Malta risks: EU anti-money laundering requirements are tightening—higher compliance costs Substance checks are increasing—real presence is becoming essential Banking is tougher—KYC procedures take months Reputation risk—Malta is on the EU’s watchlist Ireland risks: OECD minimum tax could affect the 12.5% rate Post-Brexit uncertainty for UK business Rising costs due to full employment Property bubble is making expansion expensive Netherlands risks: Growing tax harmonisation in the EU Substance requirements are getting stricter The Innovation Box may be restricted High costs make small structures unprofitable Exit Strategies: If You Want Out No one likes to talk about it, but sometimes a structure needs to be wound up. The facts: Malta: Liquidation takes 6–12 months, costs €5,000–15,000 Ireland: Voluntary strike-off possible after 3 months, costs €2,000–5,000 Netherlands: Liquidation takes 2–6 months, costs €3,000–8,000 What does this mean for you? Malta is the cheapest for taxes, but most expensive in practice. Ireland offers the best all-round package for tech companies. The Netherlands are perfect for established businesses that put legal certainty above everything else. My Recommendation: Which EU Location Fits Which Type of Company 2025 After helping over 150 company formations in all three countries, I’ve spotted clear patterns. The “best” location isn’t just about tax rates; it depends on your business model, size, and priorities. Here are my honest recommendations. Malta: Perfect for Digital Companies with High Margins Choose Malta if you: Run a purely digital business model (software, consulting, online services) Make at least €200,000 annual profit Can spend 3–6 months a year in Malta yourself Appreciate the Mediterranean work culture Seek maximum tax optimisation Concrete examples of successful Malta structures: SaaS companies: Software licensing via Malta, real development onsite Online marketing agencies: Client support and campaign management from Malta Trading companies: Crypto or forex trading with Malta license Gaming companies: Online casinos and sports betting providers Consulting firms: Management or IT consulting for European clients Not suitable for: Physical products (logistics too expensive) Pure holding structures without real business activity Businesses under €100,000 annual profit Teams unable to relocate to Malta Ireland: The All-Rounder for Tech and Innovation Choose Ireland if you: Are a tech company or innovative service provider Run R&D-intensive operations Plan international holding structures Value legal certainty above tax minimisation Need access to qualified employees Successful Ireland models from my practice: Fintech startups: Use R&D tax credits for app development Software companies: European HQ with local development team Biotech companies: Research and IP management in Dublin Holdings: Equity management with DTT optimisation E-commerce: European logistics and customer service Netherlands: The Safe Bet for Established Businesses Choose the Netherlands if you: Run an established business with over €500,000 annual profit Value legal certainty and reputation over tax optimisation Are building complex international structures Have IP-intensive business models Need excellent infrastructure Dutch success models: IP holdings: Patent and trademark management with the Innovation Box International holdings: Shareholdings across multiple EU countries Logistics companies: Rotterdam as a European hub Family businesses: Generational succession and structure optimisation Private equity: Fund management and equity structures Decision Matrix: Find Your Optimal Location Use this matrix to identify your optimal location. Assign each factor a weighting from 1–5 (5 = very important), then rate each location from 1–5 (5 = excellent): Factor Weighting Malta Ireland Netherlands Tax burden _ 5 4 2 Legal certainty _ 3 5 5 Infrastructure _ 2 4 5 Operating costs _ 4 3 2 Compliance effort _ 2 4 4 Talent pool _ 2 4 5 Reputation _ 2 4 5 Calculate: (Weighting × Rating) for each location, then sum the totals My Top Recommendations by Business Size Startup up to €50,000 annual profit: Stay local for now. EU structures aren’t worth it yet; the effort is too high. €50,000–200,000 annual profit: Consider Ireland for tech companies with R&D potential. Malta only for pure digital business models and if you can relocate yourself. €200,000–500,000 annual profit: Malta for maximum tax optimisation; Ireland for a balanced mix of tax and infrastructure. Over €500,000 annual profit: All three are possible. Netherlands for complex structures, Ireland for tech, Malta for pure tax optimisation. Hybrid Strategies: The Best of Several Worlds Advanced entrepreneurs combine locations: Ireland + Netherlands: Operating company in Ireland, IP holding in the Netherlands Malta + Germany: Operations in Malta, substance company in Germany All three: Distribute functions across multiple countries Example: My client runs a software company with €2 million annual sales. Development is through Ireland (R&D Tax Credits), IP is held in the Netherlands (Innovation Box), sales are channelled through Malta (5% tax). Complex but extremely effective. What does this mean for you? There is no one-size-fits-all location. Analyse your business model, priorities, and resources. When in doubt: start with one country and expand later. Perfection is the enemy of progress. The Most Common Pitfalls for EU Business Locations and How to Avoid Them In three years, I’ve seen literally every mistake you can make with international structures. Some only cost nerves, others six-figure sums. Here are the seven most critical pitfalls—and how to steer clear of them. Pitfall 1: Underestimating Substance Requirements The mistake: I’ll quickly set up a Malta company and just route profits through. That used to be possible, but since the EU Anti Tax Avoidance Directives (ATAD), every country is strict about substance. My client Stefan thought a Maltese director via service contract would be enough. Wrong. The Maltese tax authority classified his company as “non-substantial” and demanded €180,000 in back taxes. How to avoid it: Plan for real economic activity on-site Relocate actual decision-making processes Carefully document all activities Use local employees, not just service providers Hold regular board meetings on location Pitfall 2: Ignoring Banking Problems The mistake: I’ll sort out the bank account somehow after formation. Banking is now the bottleneck in international structures. One client waited eight months for a Maltese business account—the company was formed but couldn’t operate. Cost: €40,000 in inactive structure plus lost tax savings. Banking reality 2025: Country Average Duration Common Issues Solution Malta 3–8 months Strict KYC, source of funds Apply to several banks, use local introducer Ireland 4–12 weeks Substance proof required Local director, genuine business address Netherlands 2–6 weeks Relatively straightforward Standard process with major banks My banking strategy: Prepare the bank account application before company formation Apply to 2–3 banks simultaneously Have all documents prepared professionally Hire a local banking specialist Have a plan B with EMI/fintech providers Pitfall 3: Overlooking Double Taxation The mistake: 5% Malta tax means 5% total tax. Wrong! You also need to consider German withholding tax, potential controlled foreign corporation (CFC) rules, and more. One client ended up paying 23% instead of the expected 5%—even with a perfect Malta setup. The hidden tax traps: CFC rules: German inclusion rules for low-taxed foreign companies Exit taxation: On relocation of business assets Withholding tax: On dividends, interest, and license fees VAT: B2B business within the EU Permanent establishment: Unintended tax liability if too much activity is onshore How to check your total tax burden: Check DTTs between home and host country Analyse CFC rules of your home country Watch out for switch-over clauses Use qualified advisors in both countries Have the total tax burden calculated Pitfall 4: Underestimating Compliance Costs The mistake: Set it and forget it. International structures require ongoing maintenance. Annual reports, substance proof, transfer pricing documentation, BEPS compliance—it all adds up. One client budgeted €15,000 a year for compliance; ended up paying €45,000. Realistic compliance costs (annually): Country Basic compliance With substance Complex structure Malta €12,000–18,000 €25,000–35,000 €40,000–60,000 Ireland €15,000–25,000 €30,000–45,000 €50,000–80,000 Netherlands €18,000–28,000 €35,000–50,000 €60,000–100,000 Pitfall 5: Ignoring Legal Risks The mistake: Tax is all that matters. Wrong. Company law, employment law, data protection, and liability risks can be more expensive than tax. One client had to give up a Maltese gaming license because they violated German gambling laws. Loss: €300,000 investment. Critical legal areas: Corporate law: Director’s liability, compliance obligations Employment law: Local employment, social security Regulation: Sector-specific licenses and rules Data protection: GDPR compliance for EU-wide operations Liability: Product, professional, and D&O insurance Pitfall 6: Forgetting Your Exit Strategy The mistake: I’m planning forever. Laws change, businesses evolve, personal circumstances shift. Without an exit strategy, you’re trapped. One client wanted to wind down their Malta structure, but liquidation cost more than two years’ tax saving. Exit strategy checklist: Clarify liquidation costs and timeline upfront Calculate tax consequences of winding down Keep alternatives in the back pocket Include termination clauses in contracts Prepare documentation for future successors Pitfall 7: Overlooking Political and Regulatory Risk The mistake: EU rules are stable. Nonsense. BEPS, ATAD, EU minimum tax, digital services tax—regulation changes all the time. Malta has been on the EU’s watchlist for money laundering; Ireland may have to give up its 12.5% rate. How to protect yourself: Never bet everything on one country Actively track EU and OECD developments Plan flexibly—no rigid 10-year structures Keep options open for migration Subscribe to professional tax newsletters The Ultimate Pitfall-Avoidance Plan Phase 1 – Before Formation (2–3 months): Calculate your overall tax burden Plan substance requirements in detail Develop a banking strategy Budget for compliance costs Analyse legal risks Phase 2 – Implementation (3–6 months): Professional advice in both countries Parallel bank account applications Document every step carefully Build local infrastructure Set up compliance systems Phase 3 – Ongoing Operations (quarterly): Document substance proof Track compliance obligations Monitor regulatory changes Update your exit options Review tax optimisation What does this mean for you? International structures are like sports cars—powerful, but high maintenance. Plan conservatively, be generous with your budget, and always have a plan B. Better to spend one year planning than five years troubleshooting. Frequently Asked Questions on EU Business Locations Which EU location has the lowest corporate taxes in 2025? Malta offers an effective 5% corporate tax rate for operational profits via the 6/7 system—provided you meet the substance requirements. Ireland is at 12.5%, the Netherlands at 19–25.8%. Important: the overall tax burden, including your home country, can be higher. Can I just move my German company to Malta? No. Simply relocating triggers German exit taxation. You have to set up a new company and build genuine economic substance. The transfer of assets and IP may be taxed as well. Professional advice is essential. How long does it take to set up a company in Malta, Ireland, and the Netherlands? Malta: 2–4 weeks for incorporation, but 3–8 months for banking. Ireland: 1–2 weeks to incorporate, 4–12 weeks for banking. Netherlands: 1–2 weeks for incorporation, 2–6 weeks for banking. Allow at least 6 months from start to full operational readiness. What substance requirements do I have to meet? All three countries require genuine business activity: local employees or directors, a real office, regular board meetings onsite, local bank accounts, and demonstrable business operations. Shell companies do not work anymore. What happens with EU-wide tax harmonisation? The EU is working on a 15% minimum tax for large companies (OECD Pillar Two). Small and medium enterprises are initially exempt. Existing structures usually have grandfathering, but new regulations may restrict future optimisation. Can I combine all three locations? Yes. Many international companies use multi-jurisdictional structures: operating company in one country, IP holding in another, financing vehicle in a third. But this requires careful planning—and significantly raises compliance costs. What are the real total costs in the first year? Malta: €55,000–100,000, Ireland: €75,000–145,000, Netherlands: €75,000–130,000. This includes setup, compliance, office, staff, and banking. The actual incorporation cost is just a small fraction of the total. What are the biggest risks with international structures? Substance risks (retrospective taxation), banking hurdles (inoperable structures), compliance failures (fines and reputational damage), regulatory changes (structures become obsolete), and exit issues (expensive wind-down). Is an EU structure worthwhile for small companies? Usually not if you have less than €200,000 annual profit. Fixed costs are too high compared to the tax savings. From €200,000 it becomes interesting, from €500,000 it almost always pays off—if implemented properly. How do I find the right advisor? Look for advisors with proven experience in your target country and industry. Ask for references and check credentials. Avoid advisors offering “tax savings without substance” or promising unrealistic timelines. Serious advice costs €200–400 per hour.
