Partial value

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The present value is in Germany a rating scale for assets of the taxable business assets . It is defined as the amount that an acquirer of the entire business would apply as part of the total purchase price for the individual asset ; It can be assumed that the purchaser will continue to operate ( Section 6 (1) No. 1 sentence 3 EStG and Section 10 sentence 2 BewG ). The partial value usually corresponds to the market value or market price . It is used regularly when evaluating withdrawals and deposits . A partial value that has fallen below the cost of acquisition or production entitles to a partial value depreciation in the event of permanent depreciation .

Differentiation from other evaluation standards

The concept of partial value only exists in German and Austrian and partly in Swiss tax law. International standards of value are fair value and net realizable value . The partial value often corresponds to the commercial law term of the fair value. However, the fair value in the trade balance may differ, in particular due to the principle of loss-free valuation; according to commercial law, only losses are anticipated. In addition, no profit margin is deducted when devaluing. However, the partial value concept is based on an imaginary profit-oriented purchaser. In order for this purchaser not only to achieve no losses but also profits, he must also deduct a profit margin from the valuation.

A distinction must be made between the partial value of the book value and the intermediate value , which generally allow a lower valuation and thus allow the possibility of avoiding the (partial) disclosure of hidden reserves .

A special partial value is defined in Section 6a (3 ) EStG for the amount of pension provisions. The valuation method on which the calculation is based has acquired greater actuarial significance due to the definition in the Income Tax Act and is called the entry value method there .

Partial value assumptions

In order to make the concept of the partial value manageable, detailed specifications for the determination of the partial value, the so-called partial value assumptions , were developed by the case law :

The upper limit of the partial value is formed by the replacement costs , while the lower limit is determined by the individual selling price.

Since partial value presumptions represent an estimate, this can be done through the proof

  • lower replacement costs,
  • about the existence of a wrong measure with regard to the considered asset,
  • lower selling prices, which no longer lead to cost coverage,
  • decreased corporate profitability as well
  • decreased profitability of the asset under consideration

be refuted.


  • Lademann / Söffing / Brockhoff: Commentary on the Income Tax Act , § 6 Note 400 f.,
  • Gürsching / Stenger: Valuation law BewG ErbStG comment , § 6 EStG margin no. 76-79 mw N.