Deducting an ETF savings plan from tax: what really works, for the self-employed and shareholder-managing directors
Mikhail Iankovski, M.Sc.
Published in October 2026
Reading time 8 min
The last quarter is the season of tax conversations. Anyone who works for themselves sits down with their tax advisor over the figures for 2026 in these weeks and at some point asks: isn't there some way to deduct my ETF savings plan? The honest answer is no, and yet it is the start of a useful line of thought. Because the same asset class, broadly diversified index funds, is also available in provision wrappers funded from pre-tax income. This article explains why the private savings plan is not deductible, which routes are, who they suit and what has to happen by 31 December.
Why the private ETF savings plan is not deductible
A savings plan in a securities account is wealth building from net income. The money has already passed through income tax before it is invested, and tax law offers no deduction for it: neither as income-related expenses nor as special expenses. Returns are subject to the flat withholding tax of 25 % plus solidarity surcharge on sale or distribution (§ 32d EStG). Two things soften this: the saver's allowance of 1,000 euros a year, 2,000 euros for joint assessment (§ 20 Abs. 9 EStG), and for equity funds the partial exemption, which leaves 30 % of the returns tax-free (§ 20 InvStG).
That is not a drawback to be argued away. What the private savings plan gives up in tax relief, it gains in something the tax-privileged routes cannot offer: full availability. You can sell, reallocate or pause at any time. Anyone who needs that flexibility is well served by a securities account. Anyone who invests until retirement anyway forgoes the tax relief with a securities account and keeps the availability in return. Which side outweighs the other depends on the costs of the wrapper, the tax rate in retirement and the time horizon.
Same asset class, different wrapper
The tax-privileged provision routes work on a shared principle: the contribution is made before tax, as a special expense, a tax-free salary component or a business expense, and only the later benefits are taxed. In retirement, the personal tax rate is often below that of the working years, depending on the income situation. In the meantime, the full gross amount stays invested.
Within these wrappers, the capital can be invested in the capital markets depending on the tariff, in unit-linked variants also through broadly diversified index funds. The asset class is therefore the same as in the securities account; only the tax framework is different. Why that is not a promise of returns and which opportunities and risks come with it is set out in the article on capital market participation within an insurance framework. The price of the tax relief is the same in every case: lock-in. The funds are not available until retirement.
Simplified illustration at a marginal tax rate of 42 %, excluding solidarity surcharge, church tax, costs and investment performance, with the contribution within the relevant tax-relief limits. The chart shows when tax is levied, not an end result: in the wrapper the later benefit is taxed in retirement, in the securities account only the returns are subject to withholding tax, and the account remains available at any time. With the Basisrente the benefit comes through the tax refund; with the Unterstützungskasse it is measured against an equal gross salary. Whether the wrapper ultimately produces a higher net pension depends on the costs of both routes, investment performance and the tax rate in retirement.
Route 1 for the self-employed: the Basisrente
For the self-employed without a GmbH, the Basisrente is the most direct tax-privileged route. Contributions count as special expenses under § 10 EStG, at 100 % since 2023. The ceiling derives from the maximum contribution to the miners' pension insurance and stands at 30,826 euros in 2026, 61,652 euros for jointly assessed spouses. Important: this ceiling applies to the entire basic provision, including contributions to the statutory pension scheme or a professional pension fund. What is already used up there is no longer available for the Basisrente.
The lock-in is strictest here: the benefit comes as a lifelong pension, at the earliest from 62, and it cannot be taken as a lump sum, pledged or transferred. In return, the frame is large even for high incomes. The assessment for chamber professions with a professional pension fund is in the article on retirement provision for freelancers.
Route 2 for employees and managing directors: the tax-privileged company pension
Anyone who draws a salary, including as managing director of their own GmbH, can use direct insurance. Contributions are tax-free in 2026 up to 8,112 euros a year (8 % of the contribution assessment ceiling, § 3 Nr. 63 EStG), half of that also free of social insurance contributions for employees subject to social insurance. The route is quick to set up and clearly regulated; for shareholder-managing directors, the same formal requirements apply as for any promise to a shareholder: written agreement, shareholder resolution, appropriateness. Its limit is the fixed frame: for a retirement target at entrepreneur level, it rarely suffices on its own.
Route 3 for shareholder-managing directors: the Unterstützungskasse
The widest frame is open to shareholder-managing directors. The GmbH grants a pension promise and funds it through a reinsured Unterstützungskasse. The contributions reduce the GmbH's profit as a business expense (§ 4d EStG), no taxable income accrues to the managing director today, and only the benefits in retirement are taxed (§ 19 EStG). There is no fixed contribution cap; the yardstick is the appropriateness of the provision. The reinsurance can be invested in the capital markets depending on the tariff.
The route demands a stable earnings position, because the contributions must remain level or increase under § 4d EStG, and a clean structure, because the tax office scrutinises promises to shareholder-managing directors closely. The mechanics are in the article on the Unterstützungskasse for shareholder-managing directors, and the limits are set out candidly in the article on the drawbacks of the Unterstützungskasse.
euros deductible, returns subject to withholding tax
For: everyone
Available: at any time
euros a year deductible as special expenses, § 10 EStG, less statutory pension or professional scheme contributions
For: mainly the self-employed without a GmbH
Available: lifelong pension from age 62
euros a year tax-free, § 3 Nr. 63 EStG
For: employees and managing directors with a salary
Available: from retirement
no fixed contribution cap; the limit is appropriateness: total pension provision as a guide at most 75 % of final active pay. Deductible business expense for the GmbH, § 4d EStG
For: shareholder-managing directors
Available: when benefits fall due
What has to happen by 31 December 2026
The question that counts in the fourth quarter is not only which route, but when. Each route has its own clock.
- Basisrente. The cash-basis principle applies: the contribution must be paid in 2026 to count for 2026. Depending on the tariff, top-up payments before year end can be used to exhaust the ceiling. Clarify with the tax advisor beforehand how much of the ceiling the basic provision has already used.
- Direct insurance. Contributions for 2026 must be paid to the pension provider in 2026. Setting it up usually takes a few weeks.
- Unterstützungskasse. Here the clock starts earlier. By year end, suitability must be checked (status, age and earnings position of the GmbH, tenure as managing director), the shareholder resolution passed, the promise granted and, in practice, the contribution made within the current financial year. Coordination with the tax advisor usually takes several weeks. Anyone who starts in October has time. Anyone who starts in December generally loses a year.
Check suitability
Status, age and earnings position of the GmbH, tenure as managing director
Agree key parameters
With the tax advisor: retirement target, contribution level, pledging the reinsurance policy
Resolution and promise
Shareholder resolution and written pension promise
Make the contribution
Payment in November, early December at the latest, leaving a buffer until year end.
Typical timescales; the actual time needed depends on coordination with the tax advisor. The Basisrente and direct insurance need far less lead time; there, the contribution must be paid by 31 December.
The private ETF savings plan is not deductible, and that is the price of its flexibility. Anyone who invests until retirement anyway can consider tax-privileged wrappers in which the same asset class works pre-tax, depending on the tariff: the Basisrente for the self-employed and direct insurance within a fixed frame. For shareholder-managing directors, there is in addition the GmbH's pension promise with a genuine business rationale through a reinsured Unterstützungskasse, with the contribution as a business expense and the appropriateness of the provision as the yardstick. Which wrapper fits is decided by the situation; whether it still counts for 2026 is decided by the calendar.
Frequently asked questions
Can I deduct my private ETF savings plan from tax?
No. The payments into a private savings plan come from income that has already been taxed and are deductible neither as income-related expenses nor as special expenses. The returns are subject to the flat withholding tax of 25 % plus solidarity surcharge, softened by the saver's allowance of 1,000 euros and, for equity funds, by the partial exemption of 30 %. In return, the account remains available at any time.
Can I invest in the capital markets for retirement and still deduct the contributions?
Yes, through tax-privileged provision wrappers. The Basisrente allows special expenses of up to 30,826 euros in 2026, direct insurance through the employer allows tax-free contributions of up to 8,112 euros, and for shareholder-managing directors the GmbH can grant a pension promise with a genuine business rationale through a reinsured Unterstützungskasse, whose contributions are a business expense; the yardstick there is the appropriateness of the provision, not a fixed percentage. In all three wrappers, the savings portions can be invested in the capital markets depending on the tariff, for example through broadly diversified index funds. The price is the lock-in until retirement.
What has to happen by 31 December 2026 for it to still count for 2026?
For the Basisrente and direct insurance, the contribution must be paid in 2026. For the Unterstützungskasse, by year end suitability must be checked, the promise granted and, in practice, the contribution made within the current financial year. Structuring with the tax advisor usually takes several weeks. Anyone who starts in October has time; anyone who starts in December generally loses a year.
Further reading
- Salary, bonus, dividend or company pension: which route actually delivers for a shareholder-managing director
- Retirement provision for freelancers: why the professional pension fund is a building block, not a foundation
Want to know which wrapper fits your situation and what is realistic before year end? In an initial consultation we sort out your starting position, retirement target and timeline, as a basis for coordination with your tax advisor.
This content is general information and no substitute for individual tax, legal or investment advice. Tax structuring is carried out in coordination with the client's tax advisor. Capital market investments are subject to fluctuation; statements on fund investment apply depending on the tariff. Legal bases: § 10 Abs. 3 EStG, § 20 Abs. 9 EStG, § 32d EStG, § 3 Nr. 63 EStG, § 4d EStG, § 19 EStG, § 20 InvStG; 2026 frame per the German Social Insurance Reference Values Ordinance 2026.