When Europe’s top court delivered its ruling on Germany’s Halmer case in late December, it seemed to slam the door on private equity investment in EU law firms. Yet, look closer and you’ll see PE slipping in the back door from Arizona to the U.K., Spain and beyond.

The U.K. and Australia have allowed alternative business structures (ABSs) for more than a decade. Arizona started approving them years ago and Spain’s ECIJA sold a stake to Alia Capital Partners last year so it could open new offices and attract partners.