030 555 721 370
anfrage@guhr-steuerberatung.de
Auerstr. 14, 10249 Berlin
Industry · Holdings & Family Offices
Tax advisory for holdings & family offices that want to secure wealth.
We are the tax advisory for entrepreneurs with holding structures, wealthy families and family offices. We build the right structure around your wealth – operating holding, asset-holding company, family pool, family foundation – keep dividends and capital gains almost tax-free under § 8b KStG (Corporate Income Tax Act) and plan relief and succession across generations. Nationwide, digital and with a dedicated point of contact who knows your structure.
Nationwide · 100% digital- Specialised in holdings & family offices
- A dedicated point of contact
Sound familiar?
Problems holding entrepreneurs know all too well.
We speak daily with entrepreneurs, wealthy families and family offices. This is what we hear again and again:
You hold your shareholdings as private assets.
Dividends and sale proceeds are taxed in full under the partial-income method or the flat capital-gains tax. Inside a holding, 95% would be tax-free under § 8b KStG – the capital for your next reinvestment.
Your holding misses the participation exemption.
Below the 15% shareholding threshold, the trade-tax participation exemption (§ 9 No. 2a GewStG, the German Trade Tax Act) does not apply – and your dividend unexpectedly becomes fully subject to trade tax.
Your succession is left untaxed and unplanned.
Without business-asset relief under § 13a/§ 13b ErbStG (the German Inheritance and Gift Tax Act), a handover or inheritance can trigger a tax bill payable only by selling substance – exactly what you want to avoid.
Your administrative assets break the relief test.
Too much cash, let real estate or securities inside the structure – and the administrative-assets test (Verwaltungsvermögenstest) topples the tax exemption for your business assets entirely.
Relocating abroad becomes a tax trap.
Anyone who moves abroad holding a shareholding triggers exit taxation under § 6 AStG (the German Foreign Tax Act) – a deemed capital gain on hidden reserves, without a single euro having changed hands.
Your accountant thinks in annual accounts, not in structures.
They prepare financial statements for each single entity – but no one plans the holding level, a family foundation, relief, double-taxation treaties and succession across the whole of your wealth.
What changes for you
Less tax. More structure. Wealth that lasts across generations.
We are not a classic tax firm. We deliver what you as an entrepreneur and family really need – a structure that lowers tax and secures wealth.
Dividends parked almost tax-free.
Through the operating holding, distributions and capital gains are 95% tax-free under § 8b KStG – effectively around 1.5% instead of up to 28% at the personal level. Capital that reinvests.
The right holding shell.
Operating holding, asset-holding company or family GmbH & Co. KG (a limited partnership with a GmbH as general partner) – we choose the most tax-efficient structure for each building block of your wealth and use the participation exemption wherever it applies.
Succession secured in tax terms.
We apply business-asset relief under § 13a/§ 13b ErbStG, shape administrative assets below the thresholds and transfer business assets largely tax-free to the next generation.
A family foundation as anchor.
Where it fits, we give wealth independent standing in a family foundation (Familienstiftung) – protection against fragmentation, creditors and forced-heirship claims, with the recurring 30-year inheritance-substitute tax clearly planned in.
An international structure without nasty surprises.
We check exit taxation (§ 6 AStG), controlled-foreign-company rules (§§ 7–14 AStG) and double-taxation treaties before anyone moves or acquires a foreign shareholding – not at the tax audit.
One view across the entire wealth.
Effective tax rate per structure, liquidity at holding level and reinvestment headroom across all shareholdings – you always know what can be distributed, retained or transferred.
Personally from Karsten Guhr
Large fortunes rarely fail on returns. They fail on the wrong structure: shareholdings held privately, a participation exemption left unused, and a succession no one planned ahead. This is exactly where we come in. We build the holding and foundation structure around your wealth before the next sale or handover – so that every dividend, every exit and every generation is thought through in tax terms.
We know your business
We speak holding language.
§ 8b KStG, the participation exemption, the 15% shareholding threshold, business-asset relief, the administrative-assets test, family foundations, exit taxation, CFC rules – we know how a shareholding and family wealth works in tax terms. You don't have to explain your structure to us.
- 01
Operating holding under § 8b KStG
Dividends and capital gains from corporate shareholdings stay 95% tax-free in the holding. The remaining 5% counts as a non-deductible business expense – an effective burden of around 1.5%.
- 02
Trade-tax participation exemption
The 15% threshold under § 9 No. 2a GewStG (domestic) and § 9 No. 7 GewStG (foreign) decides whether dividends stay free of trade tax. We structure shareholdings cleanly above the threshold.
- 03
Asset-holding vs. commercial
Whether your holding is asset-holding or commercially characterised determines trade tax, the interest barrier and relief. We draw the line and choose the right characterisation.
- 04
Family-office structuring
We bundle shareholdings, securities, real estate and liquidity into a clean structure, separate administrative from business assets and build tax-transparent reporting.
- 05
Business-asset relief § 13a/§ 13b ErbStG
Standard relief of 85% or full relief of 100% – with payroll and retention periods. We assess the administrative-assets test and secure the exemption at handover and inheritance.
- 06
Family pool & family GmbH & Co. KG
Anticipated succession using the ten-year gift-tax allowances, with usufruct and staggered transfers – wealth moves at low tax, while control stays with you.
- 07
Family foundation & 30-year tax
The family foundation gives wealth lasting independent standing and shields it from fragmentation – factoring in the inheritance-substitute tax (Erbersatzsteuer) that deems an inheritance every 30 years.
- 08
Relocation, treaties & CFC rules
Exit taxation under § 6 AStG, controlled-foreign-company taxation of passive foreign income (§§ 7–14 AStG) and double-taxation treaties – we plan international shareholdings on solid ground in advance.
Structure profiles
We know your structure's tax burden. And the after-tax levers.
We support over 50 holding and family-office engagements nationwide and see real structures – not sample charts. We know what effective tax burden is realistic for your structure profile, where you should be, and which levers pull your after-tax burden lower.
Effective tax burden at structure level
- approx. 1.5%Operating holdingDividends & exits 95% tax-free under § 8b KStG · retain rather than tax privately
- approx. 15%Asset-holding company / real estateExtended trade-tax relief on pure letting · characterisation drawn cleanly
- approx. 15 – 26%Family officeDepending on investment income and characterisation · aim is tax-efficient bundling
- approx. 15% + 30-year taxFamily foundationOngoing corporate-tax-like burden · plan in the deemed inheritance every 30 years
How we lower your after-tax burden – legally and systematically:
- Operating holding § 8b KStG95% tax-free dividends and capital gains keep the capital inside the structure – effectively around 1.5% instead of up to 28% at the personal level.
- Participation exemption & 15% thresholdDeliberately structure shareholdings above the 15% threshold (§ 9 No. 2a/No. 7 GewStG) so dividends reach you free of trade tax too.
- Business-asset reliefStandard or full relief under § 13a/§ 13b ErbStG transfers business assets up to 100% tax-free – provided the administrative-assets test is shaped correctly.
- Family pool & allowancesA family GmbH & Co. KG plus the ten-year gift-tax allowances, often with usufruct – wealth moves at low tax to the next generation.
- Family foundationGives wealth lasting independent standing, lowers the ongoing burden and shields it from fragmentation and forced-heirship claims – with the 30-year inheritance-substitute tax planned in.
- Retention & reinvestmentRetain profits in the holding rather than draw them privately – we reinvest the tax-free 95% capital into new shareholdings or asset classes.
Why GUHR
Tax advisory that finally thinks in structures.
We don't want to be the next advisor who only prepares single-entity accounts. We want to be the partner who makes your wealth safer, more tax-efficient and predictable across generations.
Specialised in holdings
Over 50 holding and family-office engagements in recent years – we know the typical mistakes, tax traps and structural levers, from the first holding to the family foundation.
Nationwide · digital
Set up entirely digitally. Whether your entities sit in Munich, Hamburg, Frankfurt or Berlin – we work everywhere with the same speed and without paper.
Before the transaction, not after
We review structure, relief and relocation before a sale, handover or move – not once hidden reserves have already been deemed taxed.
Personal, not anonymous
A dedicated point of contact who knows your structure, your shareholdings and your family. Answers in hours, not weeks.
More than tax advice
A network of wealthy entrepreneurial families. Included.
With GUHR you become part of a client circle you'd otherwise only meet at closed entrepreneur gatherings. Families and family offices who talk openly about structures, shareholdings, succession and foundations – because they trust the same advisor.
A selection from our holding & family-office client base
We only name specific clients with their consent. In the intro call we show you relevant cases from your niche.
What this means for you in concrete terms:
- 01
Entrepreneur round-tables
Quarterly small-group meetings – topics like building a holding, business-asset relief, family foundations, exits and international structure. By invitation, under NDA.
- 02
Peer benchmarks
We mirror your key figures anonymised against comparable structures of your size and profile. So you see where your effective tax rate really stands.
- 03
Partner network
Looking for an M&A advisor, a notary specialised in foundations, an asset manager or an off-market shareholding? We connect you directly.
Head office Berlin · clients from Sylt to Garmisch
Nationwide · 100 % digital
One firm. Available anywhere in Germany.
Whether Berlin, Munich or somewhere in between: we run every mandate fully digital – DATEV-connected, signed PDFs, video meetings. No commuting, no postal delays, no 90s-style bookkeeping.
- 01
DATEV Unternehmen online
Receipts, banking, payroll, reports – you work in the standard interface every German tax advisor speaks. No vendor lock-in.
- 02
Video meetings instead of on-site visits
Quarterly review, tax strategy, holding check – via video with screen sharing. You save half a day every time.
- 03
Signed PDFs & digital powers of attorney
Tax filings, annual accounts, contracts – signed via qualified e-signature. Accepted by the tax office, done in minutes.
How we work with holdings
From intro call to a tax-optimised structure.
On average 14 days from the decision to switch to running digital operations.
Intro call & structure check
30 minutes. We review your shareholding structure, effective tax rate and the biggest levers across the whole of your wealth – free and non-binding.
01
Onboarding in 14 days
We handle the switch from your previous advisor, set up DATEV and connect banking, shareholding accounting and your existing reporting.
02
Structure & ongoing support
We implement the right structure – holding, family pool, foundation – and deliver ongoing group figures, deadline monitoring and proactive alerts before every transaction.
03
Annual review & strategy
Financial statements, tax optimisation and a clear plan for distribution, reinvestment, relief and succession – not a look back, but a roadmap across generations.
04
030 555 721 370FAQ
Answers for holding entrepreneurs.
The questions we're asked most before you switch.
Intro call for holdings & family offices
What your structure gives away in tax – we show you in 30 minutes.
You outline your structure, we name the concrete levers (§ 8b KStG, the participation exemption, business-asset relief, family foundation, exit taxation) and send a written proposal within 48 hours. Nationwide, free and non-binding.