GUHRSteuerberatung

Sparringspartner für Unternehmer.

Service · Tax structuring

A holding structure that works for you.

With the right holding architecture, dividend income is no longer taxed at 26.4% privately – it sits at 1.54% inside the holding. We design the structure for your margin, exit horizon, family situation and relocation plans.

  • Audit-proof implementation
  • Lock-up periods accounted for
  • Exit & succession in view
1.54%Effective tax on dividends inside the holding
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.

P01Highly complex

Holding setup & restructuring

For whom: GmbH directors with profit ≥ €100k

Upside

Park dividends almost tax-free (1.54%) in a holding

Pitfalls
  • 7-year lock-up under §22 UmwStG
  • Real-estate transfer tax on property
  • Ongoing administration cost
P04Highly complex

Operational split (Betriebsaufspaltung)

For whom: GmbH directors with real estate + operating business

Upside

Avoid the trap – or use the split deliberately

Pitfalls
  • Personal and asset interlocking
  • Forced commercial classification
  • Withdrawal complications
P02Demanding

Choosing & changing legal form

For whom: Sole traders, partnerships → GmbH

Upside

Save up to €50k/year via the GmbH wrapper

Pitfalls
  • Trade-tax trap for professionals
  • Contribution lock-up
  • Loss carry-forward does not transfer
P14Highly complex

Tax-neutral contribution under §20 UmwStG

For whom: Sole traders, partnerships

Upside

Move into a GmbH structure tax-neutrally

Pitfalls
  • 7-year lock-up
  • Real-estate transfer tax risk
  • Book-value election deadline
P12Highly complex

Liquidation & conversion

For whom: GmbHs going through structural change

Upside

Preserve hidden reserves during structural change

Pitfalls
  • Lock-up under §6 (5) EStG
  • Loss carry-forward is forfeited
  • Loss of professional-services privilege
P23Highly complex

Tax group (Organschaft)

For whom: Holding + subsidiary GmbH

Upside

Offset subsidiary losses against parent profits immediately

Pitfalls
  • Breaking the profit-transfer agreement voids 5 years retroactively
  • Minimum compensation payment required
  • 5-year minimum term
P50Highly complex

Spin-off & demerger

For whom: GmbH directors with multiple business lines

Upside

Cleanly separate risk and assets, tax-neutrally

Pitfalls
  • Real-estate transfer tax trap
  • UmwStG lock-up periods
  • Creditor protection under §133 UmwG
P28Highly complex

Election to GmbH taxation under §1a KStG

For whom: Partnerships with high profits

Upside

GmbH-style taxation without changing legal form

Pitfalls
  • Reversing the election triggers hidden reserves
  • No real GmbH liability shield
  • Partner changes are complex
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.