A five-country manufacturing group, rebuilt around one holding

The group had grown by buying companies, and each acquisition had been bolted on wherever it was convenient at the time. Dividends crossed three borders before reaching the family, losing withholding tax along the way.

Group financing ran through the German parent with no transfer pricing to support it, procurement for all five factories sat in a company with two employees, and the US subsidiary's profits were stuck because repatriating them was expensive.

1. 1Mapped every flow of money in the group: dividends, interest, management fees, royalties and trade.
2. 2Placed a single holding company in the Netherlands with real board substance, and moved the operating companies under it in a tax-neutral reorganisation.
3. 3Moved group procurement to the Polish company, where the purchasing team actually works, and priced it with a documented margin.
4. 4Refinanced intra-group debt at arm's-length rates with documentation, and set a repatriation plan for the US profits under the treaty.
5. 5Aligned the family's own shareholding and dividend policy with the new structure.

About EUR 4.8m a year less tax and withholding across the group, from a group effective rate near 29% to around 22%.

One holding, one set of intercompany agreements, and a structure the next generation and any buyer can understand.