Defenition: According to Section 6 (1) EStG and Section 10 BewG, the partial value is the amount that an acquirer of an entire company would apply under tax law within the framework of the total purchase price for the individual asset. It relates to the circumstances of the company that the asset to be valued serves. Its determination assumes three fictions that are difficult to understand in operational reality:
Value and the earnings value
(1) The partial value is next to the common value and the Earned value a main tax asset. The benchmark is initially § 6 EStG, based on the acquisition or production costs. The partial value is based on the fiction of a business sale according to the principle of individual valuation. The upper limit of the valuation is the acquisition or production cost. In the event of a permanent decrease in value, a lower valuation can be chosen.
In this context, a mandatory write-up was introduced. The strict Lowest value principle of the HGB for current assets is broken (relevance of the commercial balance sheet for the tax balance sheet).
(2) Original assessment standard of the Assessment Act according to § 10 BewG in addition to other main values. The partial value is the yardstick for the valuation of a company's assets within the framework of the standard valuation of business assets. The decisive factor is a value that an acquirer of the entire company would apply as part of the total purchase price for the individual asset under the premise of the going concern (continuation of the company).
Replacement costs
The replacement costs represent the upper limit of the valuation, a valuation above the historical acquisition or production costs is therefore permissible. However, the valuation from the tax balance sheet is usually decisive (transfer value). The partial value is therefore used as an exception value for commercial and liberal professions that are not included in the balance sheet.
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