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SMBs & agencies · Liability notice

Liability notice (Haftungsbescheid) — challenging managing director or wage tax liability

The tax office must give reasons for two discretionary decisions: whether anyone is held liable at all, and which of several responsible persons.

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Quick check: what should you do?

3 short questions — no sign-up required.

Was the company in financial crisis during the liability period?
Does the liability amount threaten your personal livelihood?

Deadline at a glance

1 month from notification

§ 355 AO

The objection must reach the tax office within one month of notification (deemed notification: 4 days after dispatch) — at the same time, suspension of enforcement (§ 361 AO) should be requested.

It is an AI, not a person: nobody looks at your individual case, and we do not know who signs up or for what reason. That is why we give pointers, but no legal advice on the individual case. Guidelines and playbooks in the platform are only guardrails: the AI relies on the available sources and your information. AI can make mistakes — check important results, and if in doubt, ask a lawyer.

Typical risks in this scenario

What we pay special attention to

Curated from real cases. The AI review flags exactly these points in your document.

  • Without a documented repayment ratio, the accusation of gross negligence is difficult to refute.

  • A wrongly reasoned exercise of discretion in selecting the person liable (why precisely this person) is rarely challenged.

  • Without suspension of enforcement, enforcement looms despite the pending objection.

What you can do here in 5 minutes

A liability notice (Haftungsbescheid) under § 191 AO holds a person liable for another's tax debts — typically managing director liability (§ 69 i. V. m. § 34 AO) or the employer's wage tax liability (§ 42d EStG). There must be an intentional or grossly negligent breach of duty that caused the tax loss; the discretion on whether to act and whom to select (Entschließungs- und Auswahlermessen) must be reasoned in the notice.

Upload the liability notice — our AI tools check the exercise of discretion, fault and the repayment ratio and prepare an objection (Einspruch) together with an application for suspension of enforcement.

How it works

Results in three steps

1

Check the discretion

Cross-check the discretion on whether to act and whom to select in the notice — missing reasons can be challenged.

2

Document the repayment ratio

Evidence the company's liquidity during the liability period (principle of proportionate repayment).

3

Objection + suspension

An objection that preserves the deadline, with an application for suspension of enforcement (§ 361 AO).

What you get
  • Check the discretion – Cross-check the discretion on whether to act and whom to select in the notice — missing reasons can be challenged.
  • Document the repayment ratio – Evidence the company's liquidity during the liability period (principle of proportionate repayment).
  • Objection + suspension – An objection that preserves the deadline, with an application for suspension of enforcement (§ 361 AO).
What it is not
  • No tax planning advice.
  • No insolvency law advice.
  • No representation before the finance court.

Transparency

What the AI checks — and what only a lawyer can decide

An AI is only as good as the question. We show openly where your answer is reliable and where you should speak with a lawyer.

Practically always where a GmbH managing director is held liable — a tax adviser or specialist lawyer for tax law (Fachanwalt).

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