I seem never to have dealt with this problem in the blog. So I’ll quote myself on ProZ, where you can see others’ opinions too:
seat
Explanation:
I prefer seat, because it is understood in English and doesn’t give the incorrect impression that it is a street address (unlike ‘registered office’). It is unpopular with some translators because it is perceived as ‘translatorese’, but in legal translation you can’t just take the nearest potential equivalent just because it sounds English – because, after all, we’re talking about German law, not English law.
I agree that ‘domicile’ is a possibility, but I don’t think it’s so widely understood (and a German domicile is a city, but an English domicile is a jurisdiction, such as Germany or England and Wales or California). ‘Corporate headquarters’ seems a slightly different context to me.
Here’s another one, where the asker said:
Please do not reply with seat. It sounds very awkward to me.
I am translating it as headquarters but wondering why I can’t say location.
Don’t you just love it when someone tells you what answer they don’t want? And even Beate Luetzebaeck hates seat.
Actually, the term seat is not so uncommon in company-law contexts, for instance in seat theory (PDF); Sitztheorie).
At present, there are two contrasting conflict of law theories as regards the recognition of foreign
legal persons: the ‘incorporation’ theory and the ‘real seat’ theory. The ‘real seat’ theory probably
dates back to the middle of the nineteenth century. According to this theory, the law of the country
where the company has its ‘real’ seat (i.e. its management and control centre) is the law applicable to
company relationships.
People may not like the word seat, but registered office
strikes a really odd chord for me, since a registered office is an address, for instance an address for service, whereas Sitz is a town, for example the courts of that town.
The German text might be:
Sitz der Gesellschaft ist Hamburg.
You can’t write: The company’s registered office is Hamburg.
But you might write: The company’s registered office is in Hamburg.





