I don't know much about the legal details, but I imagine it would have to be. After all, the purpose of the company would be to offer Google services in German

I don't know much about the legal details, but I imagine it would have to be. After all, the purpose of the company would be to offer Google services in Germany - so I imagine, it would either be a subsidiary or a de-facto shell company. Good point though, that sort of answers my question already.