Cross-border private markets,
made plain.

Plainly LP is the coordination layer for international investors in US funds, SPVs, and syndicates. Clarity on structure, obligations, and risk. One point of contact across the entire process.

0%
US withholding tax on distributions
without a correctly filed W-8BEN/E
0k+
Potential tax cost difference between
optimal and worst-case structure at 5x
§0
German unified tax assessment
no individual advisor can file alone

Three parties. Zero coordination.

When a German investor puts money into a US fund, nobody is responsible for what happens next on the local side. US funds focus on US tax and operations. They are not responsible for non-US obligations. German tax advisors are unfamiliar with US fund structures and K-1s. The investor is left to piece it together alone.

The result is missed filings, incorrect withholding, phantom taxation, and in some cases tax bills that dwarf the original investment gain. The gap is real. It is largely unmanaged. And it is structural.

US side
Fund administrator
(Finally Fund Admin)
Coordination layer
Plainly LP
Germany side
Investor and local
tax advisor

Not tax advice. Not fund administration. Coordination, preparation, and navigation across every stage of the investor lifecycle.

01
Structural
opinion
One-time assessment per fund structure and Operating Agreement. Shared across all German investors in the same fund.
  • Asset management vs. commercial activity
  • Transparent vs. opaque classification
  • Risk identification: Hinzurechnung, §180 AO, W-8BEN/E
  • Practical handover for your own tax advisor
02
Investor
onboarding
W-8BEN/E guidance, §180 AO coordination where required, and a complete handover package for your local advisor.
  • W-8BEN/E filing support
  • Correct registration with fund admin
  • AStG threshold confirmation
  • Tax advisor handover document
03
Annual
service
Ongoing coordination for K-1 preparation, unified tax assessments, renewal tracking, and law changes.
  • K-1 structuring for German tax advisor
  • §180 AO annual coordination
  • W-8BEN/E renewal tracking every 3 years
  • One point of contact, always
04
Exit
support
Collection of exit documentation from the GP and fund admin. A structured handover package when the moment arrives.
  • Exit documentation collection
  • Structured handover for tax advisor
  • GmbH or private investor framing
  • Ready when the fund is ready

Two investor types.
Different risks. Different priorities.

The first question of every engagement. Everything downstream depends on whether you invest as a private individual or through a German holding company.

Track A

Private investor

Investing as a German individual directly into a US fund or SPV. The classification question is critical. A misstep can mean the difference between 26% tax and 50%+, or paying German tax on money you have not yet received.

Broader tax base. When Germany classifies the LLC as opaque, it taxes the full distribution, not just your gain.
Phantom taxation. If German LPs collectively hold over 50% of the fund, income is attributed annually before any exit.
§180 AO. A mandatory unified filing that no individual advisor can complete alone. Without coordination, it goes unfiled.
W-8BEN/E. Without a correctly filed form, 30% US withholding applies to all distributions.
Optimal scenario
~€109k
Worst case
€250k+

Based on €100k investment, 5x exit, 7-year hold. Tax cost at fund level only.

Track B

GmbH holding

Investing through a German holding company. The tax profile is significantly more favourable. 95% of capital gains are exempt under §8b KStG, producing an effective rate around 1.5% on exit. The risks shift to compliance and threshold monitoring.

AStG threshold. Total German ownership across all investors in the same fund must stay below 50%. Nobody currently tracks this.
W-8BEN/E. The GmbH must file as an entity. Incorrect filing triggers 30% US withholding on all distributions.
§180 AO. Required if the fund is classified as transparent and more than one German LP is invested. Penalties apply annually if missed.
Phantom taxation. If German investors collectively exceed 50%, the GmbH pays approximately 30% tax on undistributed income annually.
Optimal scenario
~€5k
Worst case
€156k+

Based on €100k investment, 5x exit, 7-year hold. Tax cost at fund level only. Distribution to private shareholder triggers additional Abgeltungssteuer.

The 12-item checklist
for German LPs in US funds.

Most German LPs investing into US funds are missing at least three of these twelve items. Some are missing all of them. Covers the Rechtstypenvergleich classification analysis, W-8BEN/E filing, §180 AO unified tax assessment, AStG threshold monitoring, K-1 preparation, and exit documentation.

One email. One document. No follow-up sequence.

Germany is
where we start.

The problem exists across Europe and globally. Different intensity in each market, the same structural gap. Austria is near-identical to Germany. The Netherlands, Switzerland, Belgium, Luxembourg, France, Italy, Spain, Ireland, the Nordics, and the UK all have variants of the same challenge.

The methodology built for Germany transfers. The relationships built with LPs, advisors, and funds compound. Education is the wedge. Community is the moat.

Education
Webinars, LP guides, newsletters, office hours, and cross-border investing explainers. Free content builds trust before LPs need support.
Community
LP dinners, investor salons, family office gatherings, and emerging manager nights in Berlin, Munich, and Frankfurt.
Network
An opt-in matching layer connecting LPs invested in the same funds. Fully consent-based, privacy-first.
Ecosystem
A trusted network of tax professionals using shared workflows, standardized onboarding, and K-1 coordination processes across markets.

We are building this.
Be part of it from the start.

We are in the early stages. The first cohort of investors will help shape the service, inform the workflow, and contribute to something that does not yet exist properly anywhere.

No commitment. No invoice. Register your interest and we will be in touch to understand your situation.

Already working with Finally Fund Admin or Venture University? Mention it and we will make sure the right conversation happens.

No spam. No sales calls. We will read every submission and respond personally.