Concealed deposits are de facto the counterpart to hidden profit distributions. They exist when a shareholder grants asset advantages to “his” corporation outside the regular deposits. A hidden deposit sometimes leads to fictitious disposals at the shareholder and to an inflow into the tax deposit account at the company. We show what hidden deposits according to § 8 (3) sentence 3 KStG are, how you recognize them and legally safely avoid them.
A concrete definition can be found in the Corporate Tax Directives (KStR), more precisely in R 8.9 paragraph 1 KStR. Accordingly, there is a hidden deposit if
This article does not replace tax or legal advice in an individual case. Facts, current law, jurisdiction, documentation and implementation remain decisive.