Management & permanent establishment
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AO
International Business Formation & Coordination
Your US LLC at a fixed price or your company abroad: formation, account and ongoing obligations from one source.
You receive a documented company structure with formation records, responsibilities and a calendar of ongoing obligations. We align formation and banking preparation so that each step uses consistent information. Legal and tax matters are handled by professionals you appoint directly; GCS supports the agreed implementation through to handover.
Countries and formation planning
- USA The LLC is our core product: affordable, fast, fully online and with no presence required. Without US business activity there is usually no US income tax; taxation follows your residence. In any US state, corporations on request.
- Cyprus and Malta EU company structures aligned with the business model and local requirements.
- Poland Business activity in the EU with a review of the appropriate legal form.
- Georgia Formation and banking preparation are considered together.
The country directory explains our main areas of focus. Before an engagement, we establish the specific scope and required professionals. Projects in the United Kingdom or the United Arab Emirates are assessed separately.
What we coordinate
- Entity selection and formation processes per jurisdiction
- Banking and account opening workflows
- Cross-border entity structures and their interfaces
- Documentation and process timelines
- Expansion steps into new markets
How we work
Formation filings, legal drafting and regulated services are performed by qualified licensed partners in each jurisdiction. Our contribution is the coordination layer: a clear sequence, clean interfaces and a single point of orientation for the whole process.
We make no representations regarding tax, legal or regulatory outcomes — those questions belong to the licensed professionals we coordinate with.
From a German perspective.
Controlled foreign companies
Control, income type and actual taxation matter. The low-tax threshold is below 15% (as of 09/2026); EU/EEA substance rules require evidence.
Sections 7–13 AStGForeign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AOExit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStGRemaining German interests
German nationals meeting all relevant conditions may face extended limited taxation for up to 10 years after the departure year (as of 09/2026). Preferential taxation alone is insufficient.
Section 2 AStGTax treaties
Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty statusThis overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.