GUHRSteuerberatung

Sparringspartner für Unternehmer.

Service · Director pay & private

Your compensation. Your margin. Your rules.

Salary, bonus, pension commitment, shareholder loan, dividend – every lever has a price tag and a hidden-distribution trap. We set the mix so you save €5–50k per year without the next tax audit knocking.

Optimise compensationJump to the catalogue→
  • Arm's-length comparison on file
  • Hidden-distribution risk reviewed
  • Asset-holding GmbH in view
up to €50kannual saving from a clean pay mix
8Structures in this area

Structuring catalogue

What we actually build for you.

Every card represents a real structure we implement for comparable mandates. Green is the upside, red is the pitfall – so you see where the lever sits and what we need to safeguard.

P03Demanding

Director pay optimisation

For whom: Controlling GmbH directors

Upside

Save €5–30k/year via the right pay mix

Pitfalls
  • Arm's-length comparison
  • Resolution required before year start
  • Hidden-distribution trap on retroactive top-ups
P05Demanding

Hidden-distribution audit (vGA)

For whom: All GmbH directors

Upside

Remove €5–50k of risk from day-to-day practice

Pitfalls
  • No retroactive cure
  • Stricter rules for controlling directors
  • Tax auditors' favourite topic
P11Highly complex

Director pension commitment (direct promise)

For whom: GmbH directors

Upside

Provision is deductible now; tax only on pay-out

Pitfalls
  • Excessive promises trigger hidden distributions
  • Earn-out period must be ≥10 years
  • Re-funding risk if interest rates move
P91Demanding

Bonus & advance profit allocation

For whom: GmbH directors

Upside

Flexible pay component – smooths the tax peak

Pitfalls
  • Resolution must be timed before year-end
  • Capped at 75% of annual surplus
  • Arm's-length comparison
P90Demanding

Retain vs. distribute profits

For whom: GmbH directors

Upside

Low corporate + trade tax instead of 45% income tax – interest benefit

Pitfalls
  • Later distribution still taxed at 26.375%
  • Liquidity locked in
  • No private loss offset
P33Established

Flat tax vs. partial-income procedure (§32d)

For whom: GmbH directors with ≥ 25% stake

Upside

Partial-income procedure saves up to €8k/year on large dividends

Pitfalls
  • Annual election required
  • Only beneficial if personal rate × 60% < 26.375%
  • Election binds for several years
P43Highly complex

Asset-holding GmbH ('piggy-bank GmbH')

For whom: GmbH directors with surplus liquidity

Upside

Tax capital gains at 1.54% instead of 26.375%

Pitfalls
  • §8b only from 10% participation
  • €2–5k/year running cost
  • No private speculation period
P46Demanding

Shareholder loans & financing

For whom: GmbH directors

Upside

Interest from the GmbH becomes capital income, not a hidden distribution

Pitfalls
  • Arm's-length rate mandatory
  • §8a KStG interest barrier
  • Over-collateralisation = hidden distribution
Which of these fits your situation?In a 30-minute strategy call we map your situation onto the catalogue and name the two or three structures with the biggest effect for you.
Book the strategy callFees & terms→030 555 721 370