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.

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 with taxable income below ~€96,820 (2024) pay no Soli at all
• A graduated relief zone tapers the burden up to that limit
• 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.

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:

• Corporate income tax (KSt): 15 % of taxable profit
• Soli: 5.5 % of corporate income tax
• Effective Soli burden: 15 % × 5.5 % = 0.825 % of profit

Nominally small, but it shows up on every single tax assessment your GmbH receives — including quarterly prepayments.

Worked example: how much Soli a GmbH pays in 2026

A GmbH posts a taxable profit of €80,000 in 2026:

• Corporate income tax: €80,000 × 15 % = €12,000
• Solidarity surcharge: €12,000 × 5.5 % = €660
• Trade tax (multiplier 400 %): ~€11,200
• Total tax: ~€23,860 (≈29.8 % effective)

Without Soli the bill would be €23,200. The €660 isn't pocket change — it's a real line item in your annual planning.

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:

• Capital gains tax (KapESt): 25 % of the distribution
• Soli: 5.5 % of KapESt = 1.375 %
• Total withholding: 26.375 % (without church tax)

A €100,000 gross distribution arrives as €73,625 net in your account. The Soli exemption threshold on capital income is so low that normal distributions never fall under it.

Holding structures: how to legally cut Soli to almost zero

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

For a holding GmbH receiving €100,000:

• Taxable: 5 % of €100,000 = €5,000
• KSt thereon: €5,000 × 15 % = €750
• Soli thereon: €750 × 5.5 % = €41.25

Instead of €660 Soli on the full profit, only ~€41 falls at the holding level. Minimum participation: 10 % for trade tax and 15 % for the corporate-tax subsidiary.

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 in January 2025 that Soli remains constitutional — including for companies. Political debate around full abolition continues, but no reform is planned for 2026.

For your GmbH that means: keep budgeting it, and reduce it where possible through a holding structure or systematic 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. 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.