I have had jobs where I go from the utilities "combination" meter/breaker box (that they install at the road).
This is an underground set-up. I then run my conduit underground & stub it up (before the slab is poured) inside the garage. Install my panel at that location. Last house, the owner wanted to pre-wire for future hot tub, & future shed out back. He also was going to have a counter top microwave somewhere in the kitchen (so I made the small appliance circuits with just 2 or 3 openings on them.
All of this had changed from when panel was originally installed, but luckily the 40 circuit panel had enough spaces, with 1 left.
Hard to anticipate what customers "might" want, without going to an extreme panel size!:jawdrop: