Real estate asset management for family offices, holdings and institutional investors from €10 million in portfolio volume. Strategic portfolio management, tax structuring (§ 9 Nr. 1 S. 2 GewStG, RETT blockers), transaction support — fully integrated into your holding and tax structure.
Institutional real estate investors, family offices and holding companies do not think in square metres — they think in returns, risk profiles and tax efficiency. TABAK Consulting delivers exactly that: strategic portfolio management, structuring and transaction support, fully integrated into your holding and tax landscape.
We are not a conventional property manager. Our engagement begins where owners face strategic decisions: Which structure minimises the RETT burden on the next acquisition? How do you make clean use of § 9 Nr. 1 S. 2 GewStG? Which holding level is optimal for the planned exit?
Day-to-day property management, WEG (condominium) administration and rental management are services we deliberately do not offer — for those, we recommend specialised management providers from our network. Our focus: everything that needs to be shaped in terms of tax, strategy and transactions.
Institutional real estate wealth demands continuous strategic direction — what to hold, what to sell, what to reposition? TABAK delivers the analysis and the structural decision — and coordinates execution through our in-house holding and tax team plus curated management partners.
Property-by-property analysis of risk-adjusted returns, tax efficiency and structural complexity — the decision basis for hold / reposition / disposal.
Identification of suitable off-market targets, structuring of the acquisition (asset deal vs. share deal), vendor due diligence support.
Sale preparation with tax-optimal structuring, leveraging the § 8b KStG privilege, vendor due diligence, discreet identification of prospective buyers.
Modernisation ROI analysis, ESG compliance, conversion concepts (e.g. office → residential), value-creation roadmap with tax effects mapped in.
Location, market and pricing analyses across Germany's top locations and selected EU markets. Data-driven investment recommendations.
A multi-property dashboard across the entire portfolio: cash flow, NAV, tax KPIs, holding consolidation — monthly or quarterly, as the client prefers.
Real estate transactions are not won at the notary's table — they are won in the structuring phase before it. TABAK supports buy-side and sell-side mandates from strategy through due diligence to closing — with the decisive advantage of a tax-integrated setup.
Target identification, pre-deal structuring, full due diligence (legal, tax, technical), negotiation support and closing coordination.
Sale preparation with vendor due diligence, tax-optimal sale structure (share deal vs. asset deal), buyer outreach and negotiation.
Transferring property-holding companies rather than the properties themselves — RETT optimisation within the statutory framework (§ 1 Abs. 2a/3/3a GrEStG).
Clean structuring via minority stakes (the 90% threshold) to avoid share transfers that trigger real estate transfer tax — documented with full legal certainty.
Comprehensive review alongside curated partner law firms and technical experts. A risk inventory tied directly to price relevance.
Notary support, transfer of leases and management mandates, integration into your existing holding structure, reporting in place from day one.
Holding real estate as private wealth means paying too much tax — and sleeping worse. A GmbH structure protects private assets, reduces the tax burden and makes exit scenarios plannable.
A real estate holding company owns stakes in several property GmbHs. Each property GmbH manages one or more properties. The holding receives dividends from the property GmbHs — 95% exempt from corporation tax (§ 8b KStG).
When a property is sold, either the property itself (asset deal) or the shares in the property GmbH (share deal) can be transferred. A share deal allows the buyer to optimise real estate transfer tax — which often supports higher purchase prices.
TABAK guides the contribution of properties into GmbH structures, coordination with the tax office (binding ruling), arm's-length documentation and the ongoing tax management of the real estate GmbH.
Dividends from property GmbH → holding: 95% tax-free (§ 8b KStG)
Tax mistakes in real estate cost you quietly — and permanently. A poorly planned sale, a missed depreciation allowance or an overlooked RETT optimisation quickly adds up to six-figure sums. TABAK puts every lever in position — before it is lost.
Straight-line depreciation (2% p.a.) vs. heritage-property depreciation (§ 7i: up to 9% p.a.) vs. increased allowances under § 7b EStG. TABAK maximises the depreciation potential of every property.
Optimisation under § 1 Abs. 3 GrEStG when acquiring company shares — up to full RETT exemption for intra-group restructurings.
The 10-year holding period under § 23 EStG, the § 6b EStG reinvestment reserve, asset deal vs. share deal — a tax-optimal exit needs at least 2 years' lead time.
§ 9 UStG: opting into VAT on commercial property enables input tax deduction on acquisition and renovation costs. Decisive for larger assets.
Family wealth from non-EU countries, family offices from across the EU and institutional investors rely on Germany as a stable real estate market. TABAK structures your entry — legally sound, tax-optimal, confidential.
Holding GmbH, special AIF, German partnership or direct investment — structured according to investor origin, tax profile and exit horizon.
Using Germany's double taxation treaties to reduce withholding taxes on rental income, capital gains and dividends — with substance-based compliance.
Building genuine economic substance for the German holding entity — protected against CFC taxation and documented in line with BEPS.
GwG-compliant client identification, transparency register filings, source-of-funds evidence — at institutional standard.
Coordinated structures across the DACH region and selected EU jurisdictions (NL, LU, AT, CH) — with vetted partner law and tax firms.
The entire engagement under NDA. Discreet communication, tiered information access, separate data rooms — at family-office level.
For institutional portfolios, it is not about rents or service charges — it is about structure, tax and timing. Optimise here and you unlock seven-figure sums. Ignore it and you give them away.
The § 9 Nr. 1 S. 2 GewStG privilege reduces the tax burden on rental income to effectively corporation tax level (15% instead of 30%). Prerequisite: exclusively asset-managing activity — cleanly structured, with no disqualifying activities.
Acquisitions via share deals (the 90% threshold under § 1 Abs. 2a/3 GrEStG) allow RETT to be structured with full legal certainty. On €50 million transactions that means a 5.0% saving (Baden-Württemberg tax rate) — €2.5 million per deal.
Sell the shares in the property GmbH rather than the property itself: 95% of the capital gain is exempt from corporation tax. On a €10 million capital gain that means roughly €2.8 million more in net proceeds.
Family offices, institutional investors and banks need consolidated reports across all property GmbHs: NAV, cash-on-cash yield, IRR, pre-tax and post-tax returns. We deliver at the push of a button — in whatever format the recipient requires.
Real estate portfolios with an operational character qualify for 85% or 100% relief. Prerequisite: correct structuring as business assets. We build the structure in advance so that a generational transfer does not cost 30% inheritance tax.
Since ATAD/BEPS, international investors must demonstrate genuine economic substance. We build your German holding structure to be substance-compliant — protected against CFC taxation and optimised for withholding tax.
For portfolios of €10 million and above: At this scale, it is not the management fee that determines your return — it is the tax structure and the transaction architecture. That is where we focus — a single optimised share deal model pays for the engagement many times over, for decades.
Fees are structured by scope and strategic volume. Fixed-price packages for defined engagement types, retainer models for ongoing portfolio management.
One-off initial analysis of your portfolio
Ongoing strategic portfolio management
Buy-side / sell-side · single engagement
All fees are net of VAT. Minimum engagement size: portfolios from €10 million or single transactions from €5 million. We do not offer conventional property management or WEG (condominium) administration — where needed, we are happy to refer you within our network of management partners.
We take on real estate mandates from around €10 million in portfolio volume, or single transactions from €5 million. For smaller holdings, the structuring effort rarely pays off — and our value lies not in volume business but in structural quality. Family offices and institutional investors are our core clientele.
No — deliberately not. Our engagement begins where structural, tax and transaction decisions are made. For day-to-day property management or WEG administration, we are happy to refer you within our curated network of specialised management partners. That way, everyone stays within their core expertise.
For institutional portfolios, practically always yes. The combination of § 9 Nr. 1 S. 2 GewStG (extended trade tax deduction), § 8b KStG (95% tax-free disposals) and RETT optimisation via share deals beats private ownership at any serious scale. The contribution itself, however, is a delicate tax matter — it must be structured cleanly to avoid triggering the disclosure of hidden reserves.
When acquiring the shares in a property GmbH (rather than the property itself), no RETT arises in principle — as long as no more than 90% of the shares are consolidated in one hand (§ 1 Abs. 2a/3 GrEStG). RETT blocker structures using minority stakes solve this with full legal certainty. For intra-group restructurings, § 6a GrEStG can also apply. We structure every transaction accordingly from day one.
The entire engagement is under NDA. Professional confidentiality under § 203 StGB (German Criminal Code) applies to all licensed professionals. Separate data rooms for sensitive transactions, tiered information access within the team, discreet communication channels — for family office and institutional mandates, this is standard, not the exception.
Talk to us about your real estate portfolio — no obligation, confidential, direct. We will show you what can be improved.
