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 ↗
03 / Our services
Residency & Relocation
Live where you want while keeping your business running. We plan the steps in your current and future country together.
You receive a coordinated relocation plan that also covers changes to your business and banking arrangements. It sets out what to resolve before departure, which evidence is needed at the new location and who handles each step. GCS coordinates implementation with the relevant professionals and documents outstanding decisions.
What we coordinate
- Country selection based on your business model and personal plans, including countries without income tax such as the United Arab Emirates
- Sequencing: exit steps, entry steps, registrations
- Coordination with your legal and tax advisers in both countries
- The interfaces to your entities and banking after the move
- A realistic timeline, and who does what along it
How we work
Immigration filings, tax assessments and legal steps are performed by qualified licensed professionals in each country. Our contribution is the architecture of the move: the order, the dependencies and a single point of orientation while it happens.
We make no representations regarding tax, legal or immigration outcomes — those questions belong to the licensed professionals we coordinate with.
German connections
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 AStG ↗Foreign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AO ↗Exit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStG ↗Remaining 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 AStG ↗Tax treaties
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.