22.09.2026 - American Football League Europe (AFLE): WINHELLER Advises U.S. Investor

Frankfurt/Main | September 22, 2026

International tax structure for professional American football league with eight European franchises

WINHELLER provided comprehensive advice to the U.S. initiator and principal investor on the structuring, establishment, and financing of the American Football League Europe (AFLE). LUMSDEN & Partners also supported the project as overall project manager, contributing its expertise in U.S. and European law.

The AFLE is a newly established European professional American football league with a total of eight franchises from seven countries, including established leading teams such as Rhein Fire (Germany) and the Vienna Vikings (Austria). Both teams have ranked among the best-known and most successful American football teams in Europe for years and give the new league significant prestige from the outset.
As part of the engagement, WINHELLER developed and implemented a tax-efficient cross-border structure. This structure includes, in particular, a central entity in Ireland, an Austrian league federation, and a German operating company responsible for organizing the league's activities.

A particular focus of WINHELLER's work was international tax planning. This included, among other things, selecting suitable European jurisdictions for licensing and league entities, analyzing withholding tax issues, applying Article 17 of the applicable double taxation agreements, and addressing VAT matters. WINHELLER also advised on controlled foreign corporation (CFC) rules and check-the-box elections in close coordination with the client's U.S. tax advisor.

“Project AFLE brings together complex tax issues and a highly dynamic international market environment in a particularly unique way,” explains attorney and partner Stefan Winheller, who led the engagement on the German side. “The challenge was to create a structure that is both tax-efficient and operationally viable for a pan-European league with a U.S. investor.”

Overall project management was handled by Dr. Robin L. Lumsden (LUMSDEN & Partners, Vienna/New York). The M&A expert, who was involved in the sale of Porsche to Volkswagen, is admitted to practice in multiple U.S. jurisdictions and advises clients in Europe on U.S. law in both English and German. He also became known for representing the Republic of Austria in the United States.

On the Irish side, the engagement was handled by Dentons LLP, while Christopher C. Braun advised from the U.S. perspective. German legal advice on contractual and corporate law matters was provided by Dr. Roger Bartens of Stolzenberg, while Marc André Schneider provided advice on sports law. WINHELLER was represented by attorney and partner Stefan Winheller (Frankfurt/Main) as well as attorney and tax advisor Tim Florian Metzmeier (Aalen).

The engagement underscores WINHELLER’s strength in complex international tax structuring, where cross-border structuring issues, the application of tax treaties, and anti-avoidance rules converge in an innovative project such as the AFLE. The project ideally combines the firm’s focus on private clients with its longstanding experience advising federations and sports organizations.

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About WINHELLER
WINHELLER is a leading German law and tax firm focusing on nonprofit law and private clients. The firm advises national and international nonprofit organizations, foundations, private individuals, and investors on all tax matters.

About LUMSDEN & Partners
LUMSDEN is an M&A boutique law firm based in Vienna, with offices in New York, Washington, D.C., and Los Angeles. The firm advises on Austrian and U.S. law (also in German) representing both clients in major U.S. litigation matters and Silicon Valley companies in their activities in Europe.