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Tax calculator · Holding
Holding calculator for German GmbH owners.
Compare in seconds what you gain in tax efficiency by holding your GmbH shares through a holding company – on exit or with ongoing dividends. Calculation under § 8b KStG (95 % exemption) versus partial-income method or final withholding tax.
- § 8b KStG
- Partial-income method
- CIT + trade tax + WHT
- Tax rates 2026
Your inputs
Extra capital with holding
€495,276
34.2% Advantage · Main driver: § 8b KStG. When reinvesting via the holding, almost all of the capital stays inside the structure.
Without holding (direct)
You hold the GmbH privately and sell – partial-income method applies.
- Total tax burden
- €525,074
- Effective tax rate
- 26.6%
Available for reinvestment
€1,449,927
With holding
Your holding sells the GmbH – 95 % tax-free under § 8b KStG.
- Total tax burden
- €29,798
- Effective tax rate
- 1.5%
Available for reinvestment
€1,945,202
That's the model. Now let's calculate your real number.
30-minute intro call: we review eligibility, sequencing, lock-up periods and liquidity effects for your exact setup – and tell you honestly whether the holding actually pays off for you. Free.
Simplified model with typical assumptions (CIT 15.825 %, WHT 26.375 %, § 8b KStG, partial-income method incl. SolZ). Not included: 7-year lock-up (§ 22 UmwStG) when contributing existing shares, special DTT constellations, exit taxation (§ 6 AStG), real-estate transfer tax for property holdings, social-security effects. The calculation does not replace individual advice.
How holding taxation works
Three mechanisms that decide everything.
- 01
§ 8b KStG – 95 % tax-free
When your holding sells shares in another corporation, 95 % of the capital gain is tax-free. The remaining 5 % is treated as non-deductible business expense and subject to CIT + trade tax – an effective rate of roughly 1.5 % instead of 25–30 %. The same principle applies to dividends between corporations, provided the holding holds at least 10 % (15 % for the trade-tax exemption).
- 02
Partial-income method on direct sale
When a private person sells GmbH shares (≥ 1 % stake), 60 % of the gain is taxable at the personal income-tax rate (§ 17 EStG). At 42 % income tax plus 5.5 % solidarity surcharge, that yields an effective rate of around 26.6 % – more than 17× the holding alternative.
- 03
Reinvestment vs. private payout
The holding advantage is largest when capital is not withdrawn immediately but reinvested inside the holding (real estate, securities, new shareholdings). Whoever wants everything in the private account pays withholding tax again on the way out – but the difference is still often six- or seven-figure on exit.
Why our calculators are serious.
Tax rates 2026
CIT + SolZ, WHT, trade-tax multipliers, partial-income method – at 2026 status (reviewed May 2026).
Practical assumptions
We calculate with the same simplifications we use in the initial call – so the model result is close to a real client case.
Transparent methodology
Every input is explained, every assumption documented. You can mirror the result against your Excel or your current advisor.
FAQ
Common questions about the holding structure.
01When is a holding worth it?
At the latest when the expected sale price of the operating GmbH exceeds the low six figures – or when relevant profits are to be reinvested annually. With pure private withdrawal and no reinvestment, the holding is less often advantageous. Our rule of thumb: above €100,000 reinvestment or exit volume, we always evaluate the structure.
02What does setting up a holding cost?
Pure formation cost (notary, chamber, commercial register, share capital) is typically between €1,500 and €4,000. Add advisory cost, which depends heavily on the setup (new formation, share-for-share exchange under § 21 UmwStG, qualified share contribution). For running costs, plan for one additional balance sheet and tax return per year for the holding GmbH.
03Are there lock-up periods?
Yes, the most important is the 7-year lock-up under § 22 UmwStG: anyone contributing existing GmbH shares to a holding at book value may not sell those shares tax-privileged within 7 years – otherwise the contribution gain II is taxed retroactively at the contributor. With careful planning this is avoidable, but it makes the timing of the structuring crucial.
04Is a holding worthwhile even without a planned sale?
Yes – whenever profits are to stay in the corporate sphere and be reinvested. Example: your operating GmbH generates a €200,000 surplus and you'd like to buy real estate. Via the holding, roughly €197,000 is available; held privately only ~€147,000.
05What does the calculator show – and what not?
The calculator models the standard case with current tax rates (CIT 15 % + SolZ, trade tax by multiplier, WHT 25 % + SolZ, partial-income method 60 %). It does not replace advice, because individual factors such as lock-up periods, existing loss carryforwards, shareholding ratios, international structures or exit taxation are not modelled.
30 minutes. A clear plan for your taxes.
In the free intro call we listen to your setup, name the levers with the biggest impact and send a written proposal within 48 hours. You decide after that.
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