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 ↗
04 / Our services
The account for your company: US payment providers for the US LLC, local banks for EU companies, prepared with a complete file.
You receive a dossier tailored to your business model, including company records, source of funds and account purpose. We clarify suitable institutions’ requirements, support your application and work through follow-up questions with you. The bank decides whether to open an account.
GCS prepares documents and coordinates the application process. Accounts are held directly in your name or your company’s name at the institution. We hold no client funds; the bank reviews and accepts or declines the application.
German connections
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AO ↗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 AStG ↗Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AO ↗Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStG ↗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 AStG ↗Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty status ↗This overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.