A real-asset position I am allocating to right now. The investor owns the equipment outright on the balance sheet of an EU company in Estonia or Slovakia. It is leased to an energy arbitrage operator in Romania at a fixed gross yield. Two exits, both profitable.
The container is a standardised industrial format. Mobile, secure, deployable on a leased plot of land. It runs in arbitrage mode: charges from the grid at off-peak rates overnight, discharges during peak demand the next day. Romania is the deployment market because its industrial electricity prices (€250 to €270 per MWh) and exchange-price spreads are among the widest in the EU, driven by renewable penetration and the PZU day-ahead system.
High industrial tariffs, large day-night spreads, and a fast-tracked permit environment give arbitrage operators consistent margin. The same model becomes applicable in other EU markets as their renewable mix and EV / heat-pump consumption grow. For now, Romania is where the spread pays best.
The container is leased to Innovatec, a Romanian operator. Innovatec is currently running 5 smaller-format containers (256 kWh each). The 2 MWh production line is scheduled to come online in Q3 2026. Innovatec is backed by two shareholders: Gabriel Gantner (30+ years entrepreneurial experience, Dalinga Holding) and Serghei Causnean (operations, energy sector). Counterparty financial verification is conducted via Risco, the screening service used by Romanian banks and leasing companies.
The investor sets up an EU company in Estonia (OÜ) or Slovakia (s.r.o.) — or uses an existing one. That company buys the equipment. Because the purchase is intra-EU, no VAT is charged. The company registers as a VAT payer in Romania and opens a local bank account. The tenant pays Romanian VAT directly to the tax authority; lease payments flow back to the EU company.
The container sits on the EU company's balance sheet as a physical industrial asset. You can visit it, inspect it, photograph it.
| Parameter | Estonia (OÜ) | Slovakia (s.r.o.) |
|---|---|---|
| Corporate income tax | 0% on retained earnings, 20% on distributions | 15% on taxable income |
| Tax base | Distributions only | Revenue minus expenses minus depreciation |
| Dividend withholding tax | 0% (under Austria DTA) | 7% |
| Depreciation shield | Not applicable | €42,857 per year for 7 years |
| Best suited for | Reinvesting profits into more containers | Maximising annual cash flow |
Gross income is the lease payment from the arbitrage operator: 20% of equipment cost annually, paid into the EU company's bank account. The operator buys electricity at off-peak rates and resells during peak demand at three to five times the price. The container handles between two and four cycles a day depending on grid conditions.
| Operating cost item | Annual | Share of revenue |
|---|---|---|
| Insurance (0.5% of equipment cost) | €1,500 | 2.5% |
| Company administration | €3,500 | 5.8% |
| Maintenance (largely remote, software) | €500 | 0.8% |
| Total OPEX | €5,500 | 9.2% |
Industrial-grade BESS cells degrade slower than mobile batteries. The first three years are essentially flat at full capacity. After that, capacity loss runs at roughly 2% per year. Manufacturer cell warranty is 10 to 15 years.
The lease includes a buyback option: after three years, the tenant has the right (not the obligation) to purchase the container. This is the natural exit for the tenant because by year three they have amortised it for five to six years on their books and walking away from configured equipment is uneconomic for them. For the investor it creates two paths.
You hold the asset for three years, collect the lease income, then receive the equipment sale proceeds. Capital comes back. You can roll it into a newer container with updated cells, restarting the cycle.
If the tenant declines the buyback (or both sides agree to extend), the lease keeps running for the useful life of the equipment. Passive income through year ten, then equipment sale at residual value (60-70%, roughly €180-210K).
Better cell chemistry could appear in 10 years. The 3-year buyback option mitigates exposure to long-horizon obsolescence.
Revenue tracks electricity-price volatility. In an EU with rising renewable share, volatility is the structural tailwind, not the headwind.
Single tenant. Mitigants: 3-month security deposit, contractual penalties, repossession rights, full re-leasing capability. Financial DD via Risco.
EU energy and tax legislation. The structural tailwind (Green Deal, fast-track permits, tax incentives) is currently aligned with the asset.
Energy contracts in EUR. Investor company in EUR. No FX exposure.
EU corporate structure is well-tested. VAT neutrality, double-taxation agreements, depreciation shield all standard.
The container is insured through Tier-1 international carriers (Allianz, Generali) against theft, vandalism, fire, and force majeure. Each unit has an integrated fire suppression system. Insurance covers full replacement value, third-party liability, and environmental damage. Romanian jurisdiction applies to the lease; physical repossession is straightforward when the container sits on land leased by the investor's company or the operator.
The EU invested roughly $390 billion in clean energy in 2025. Through 2050, planned investment is €5.6 trillion, or about €220 billion a year. Battery storage capacity must grow from 6 GW to 46 GW by 2030. That is nearly an 8x build-out.
Renewable supply is volatile by physics: solar does not run at night, wind is unpredictable. The more renewables on the grid, the more storage is needed to balance it. EVs and heat pumps stretch this further. Equipment costs are rising as metals and components get scarcer. Buying today locks in current prices while revenue tracks electricity prices upward. Early-cycle investors in this asset class capture the highest yields. As the market matures and capacity catches up, returns will compress.
| European company | An existing EU corporate vehicle, or willingness to register one (Estonia OÜ or Slovakia s.r.o.). |
| Funds in the EU | €300,000 available in a European bank account, or capable of being deployed promptly. |
| Minimum allocation | €300,000 (one container). Larger allocations possible by stacking units. |
| Asset preference | Comfort holding a physical industrial asset rather than a financial instrument. |
No pitch deck, no follow-up sequence. You read the memo. You walk in with the parts that did not check out. We go through them. If it makes sense, we go deeper on structure. If not, you walk away with a clearer view of the asset class.
Or write directly: daniil@daniilkozin.com
Memo authorship and purpose. The full memo (PDF) was prepared by ImmoLoewin GmbH in February 2026 in collaboration with the Romanian operating partner, Innovatec. It is shared for evaluation by qualified investors and is confidential.
Not a public offer. Nothing on this page is an offer to sell securities or financial instruments. The structure described is the direct ownership of physical equipment by an EU corporate vehicle controlled by the investor, leased to an energy operator under a signed contract. There is no fund, no SPV pooling, and no investment contract.
Risk and DD. Independent due diligence is recommended on: the sustainability of the 20% arbitrage yield in the Romanian energy market; the operator's track record; lease-agreement terms (rate, performance guarantees, penalties, buyback mechanics); EU structure compliance for VAT neutrality; applicability of Double Taxation Agreements; insurance scope; early-termination terms.
Past performance is not indicative. Forward-looking projections are based on operator data and may not be realised.