Solidarity Surcharge for GmbH in Germany 2026: Who Still Pays Soli?

Was Soli abolished? Not entirely. Roughly 90 % of individual taxpayers have paid no Solidaritätszuschlag since 2021, but the rule for your GmbH or UG is the opposite: it still pays 5.5 % Soli on every assessment of corporate income tax and on every dividend distribution. Nothing changes in 2026, and many founders only spot it on their first tax assessment.

In short: Your GmbH or UG still pays 5.5 % solidarity surcharge on the assessed corporate income tax in 2026. That works out to an effective 0.825 % of profit (15 % KSt × 5.5 %). On top of that, 5.5 % Soli applies to the capital gains tax on every distribution, i.e. 1.375 % of the dividend. Unlike individuals, corporations have no exemption threshold; Soli applies from the first euro of profit. It can be cut almost to zero through a holding structure under § 8b KStG.

What actually happened in 2021 (and what didn't)

The Soli Repeal Act eliminated the surcharge for most individuals on January 1, 2021. Specifically:

• Individuals below the Soli exemption threshold pay no Soli. The limit is defined on the assessed income tax and rises every year: in 2025 it stood at €19,950 of income tax (single assessment), in 2026 at around €20,350.
• A graduated relief zone then tapers the burden up to the full rate.
• Top earners still pay the full 5.5 % rate.
• Capital gains (interest, dividends) remain Soli-liable on the individual side.

What was not abolished: Soli for corporations. A GmbH or UG has no exemption limit; it pays Soli from euro one as soon as corporate tax applies. The logic is systematic: the exemption threshold ties to the ability-to-pay of a natural person, a concept that simply doesn't exist for the corporate income tax of a legal entity.

GmbH pays 5.5 % Soli on top of corporate income tax

The solidarity surcharge for corporations is calculated on the assessed corporate income tax, not directly on profit. The base is the tax, not the income:

Nominally small, but it shows up on every single tax assessment your GmbH receives, including the quarterly prepayments. Important: Soli is levied only on corporate income tax, not on trade tax. Trade tax is a municipal levy and carries no solidarity surcharge.

Worked example: how much Soli a GmbH pays in 2026

A GmbH posts a taxable profit of €80,000 in 2026 (municipal multiplier: 400 %):

That's an effective total burden of about 29.8 %. Without Soli the bill would be €23,200. The €660 isn't pocket change; it's a real line item in your annual planning. At €200,000 profit it's already €1,650 of Soli; at €500,000 profit, €4,125.

Soli on dividends: capital gains tax

Soli runs on a second front: distributions from the GmbH to its shareholders. When your GmbH makes a profit distribution to you as an individual, it withholds:

A €100,000 gross distribution arrives as €73,625 net in your account (without church tax). The Soli exemption threshold on capital income is so low that normal distributions never fall under it. Using the partial-income method instead of the flat withholding shifts the base but still triggers Soli on the resulting income tax.

Does Soli apply to trade tax too?

No. This is the most common mix-up. The solidarity surcharge is levied on exactly three taxes: income tax, corporate income tax and capital gains tax. Trade tax is excluded. In the example above, the €11,200 of trade tax is not hit by Soli; the surcharge falls only on the €12,000 of corporate income tax. That's precisely why the effective Soli burden stays as low as 0.825 % of profit.

Holding structures: how to legally cut Soli to almost zero

In a holding structure, where the operating GmbH distributes to a holding GmbH, § 8b KStG applies: 95 % of the distribution is tax-free; only 5 % counts as a non-deductible business expense and is taxed.

For a holding GmbH receiving €100,000:

Instead of €660 Soli on the full profit (or €1,375 on the direct distribution), only ~€41 of Soli falls at the holding level. The conditions for the participation exemption are a minimum holding of 10 % at the start of the calendar year for corporate income tax (§ 8b Abs. 4 KStG) and 15 % for trade tax (§ 9 Nr. 2a GewStG). Only when the holding passes the profit on to you as an individual does the distribution get taxed; until then the capital stays almost untaxed inside the structure.

Prepayments: Soli falls due four times a year

Soli isn't settled once a year. When the tax office sets corporate income tax prepayments, it automatically adds the Soli. The dates are March 10, June 10, September 10 and December 10. Keeping an eye on the prepayments avoids a large balancing payment with the annual return, and the 1.8 % annual interest on back taxes that has applied again since 2019.

Will Soli stay for companies? Constitutional court and outlook

Several constitutional complaints argued Soli became unconstitutional once the Solidarpakt II ran out at the end of 2019. The Federal Constitutional Court ruled on March 26, 2025 (2 BvR 1505/20) that Soli remains constitutional, including for companies. Political debate around full abolition continues, but no reform is planned for 2026.

A second effect, meanwhile, relieves the GmbH automatically: under the corporate tax investment package, corporate income tax falls from 15 % to 10 % in five annual steps from 2028 to 2032. Because Soli is 5.5 % of the corporate income tax, its effective burden shrinks in step: from 0.825 % of profit (2026) to 0.55 % (2032).

Frequently asked questions about GmbH Soli

Does a GmbH still pay the solidarity surcharge?

Yes. For corporations Soli was never abolished. In 2026 your GmbH still pays 5.5 % Soli on the assessed corporate income tax, with no exemption threshold, from the first euro of profit.

How high is the Soli for a GmbH?

5.5 % of the corporate income tax. Since KSt is 15 % of profit, that's an effective Soli burden of 0.825 % of taxable profit. On €80,000 of profit, that's €660.

Does a UG (haftungsbeschränkt) also pay Soli?

Yes. For tax purposes the UG is a full corporation and is treated exactly like a GmbH for Soli: 5.5 % on corporate income tax, no exemption.

Does Soli apply to trade tax?

No. Soli is levied only on income tax, corporate income tax and capital gains tax. Trade tax is a municipal levy with no solidarity surcharge.

How can a GmbH reduce the Soli?

Most effectively through a holding structure: when the operating GmbH distributes to a parent GmbH, § 8b KStG makes 95 % tax-free; Soli then falls only on the remaining 5 %. More levers under GmbH tax optimization.

Bottom line

For individuals, Soli is largely history. For GmbHs and UGs, it remains a reality: 5.5 % on every corporate income tax assessment and on every dividend, with no exemption. In 2026 that's anything from €600 to €2,500+ per year depending on profit, money that can be saved almost entirely at the parent level through a holding setup. Norman computes Soli automatically inside your corporate tax filing, reports it as a separate line, and tracks the prepayment dates; the surcharge still gets paid, but it doesn't cost you another hour of bookkeeping.