Data Carrier on Offshore Structures: 398 Suspected Cases in Germany
According to information from the Ministry of Finance of North Rhine-Westphalia (Finanzministerium NRW, Ministry of Finance of the State of North Rhine-Westphalia), the Landesamt zur Bekämpfung der Finanzkriminalität Nordrhein-Westfalen (LBF NRW, State Office for Combating Financial Crime in North Rhine-Westphalia) purchased customer data from offshore service providers at the end of 2025. The purchase was made public by a press release issued by the Finanzministerium NRW on 11 December 2025. The dpa reported on 19 October 2026 on the current status of the analysis; the report was picked up nationwide on the same day.
According to the published information, the data set comprises 3,320,148 files and folders with a volume of around 1.45 terabytes. To date, just under 400 cases with a connection to Germany are said to have been identified from it. Specifically, 398 suspected cases are mentioned. For North Rhine-Westphalia, the Düsseldorf Ministry of Finance cites 64 cases; the remaining cases are to be forwarded to the respective federal states concerned.
All cases are suspected cases. Whether taxes were evaded in the individual circumstances and, if so, to what extent must, according to the available information, be examined separately in each case. The presumption of innocence applies until a final clarification has been reached.
Origin and Content of the Purchased Data
Offshore Service Providers in Several States
According to the Ministry, the data comes from offshore service providers based in several states and territories. The following are named:
- Cayman Islands,
- United Arab Emirates,
- Hong Kong,
- Mauritius,
- Panama,
- Singapore,
- Cyprus.
In the dpa reporting, Dubai in particular is mentioned in this context. The official announcement, by contrast, refers to the United Arab Emirates.
According to the Ministry of Finance, the service providers offered their customers the opportunity to establish foreign companies in low-tax jurisdictions. The suspicion is that such structures may have been used to conceal assets from the German tax authorities and to circumvent tax obligations. The available information does not indicate any final and binding finding regarding individual persons or companies affected.
Beneficial Owners Also Outside Germany
According to the official account, the data set does not concern exclusively beneficial owners resident in Germany. It is also said to include persons resident in other states. A connection to Germany has been identified for the 398 suspected cases mentioned to date.
At the time of the purchase, the Ministry of Finance was unable to provide any information on the amount of funds that may have flowed into the overseas companies. The financial scope of the structures concerned therefore remains open based on the information published to date.
Suspicion of Concealed Ownership Structures
Use of Nominee Directors or Nominee Shareholders
According to the official account, nominee directors or nominee shareholders are said to have been interposed in some cases before the foreign companies. The suspected purpose of such arrangements was to shield the actual ownership structures from the tax authorities.
Here too, this is a suspicion communicated by the authorities. Whether an individual structure was impermissible for tax purposes, whether tax-relevant information was omitted, and whether tax evasion has occurred can only be assessed on the basis of the specific individual case.
Examination of Possible Tax Understatements
According to the information from the Ministry of Finance, it must now be examined in each identified case whether taxes were evaded and, if so, in what amount. The dpa report points out that cases outside North Rhine-Westphalia will be forwarded to the respectively competent federal states.
On the day the data purchase was announced, the Ministerium der Finanzen NRW (Ministry of Finance of North Rhine-Westphalia) also informed the Federal Government and the other federal states about the purchase. This is intended to coordinate the further analysis nationwide insofar as other jurisdictions are affected.
Role of the LBF NRW in the Analysis
Purchase from a Whistleblower
According to the official wording, the data carrier came from a whistleblower. In the dpa reporting, the term informant is used for this. The LBF NRW is said to have examined the material before the purchase and assessed it as highly valuable information for uncovering tax evasion.
The LBF NRW is a comparatively young authority. It consolidates tax investigation in North Rhine-Westphalia. The authority had previously attracted nationwide attention, among other things, through a “task force” in connection with tax matters involving influencers.
Experience with Offshore Data
According to the North Rhine-Westphalian tax administration, searches had already been carried out in offshore proceedings in the months before the data purchase. According to the official account, the NRW tax investigation authorities are regarded as experienced in the analysis of offshore data.
NRW Finance Minister Marcus Optendrenk told dpa that anyone hiding money through shell companies in tax havens must know that the tax investigation authorities in North Rhine-Westphalia will continue their work. He also pointed out that persons who had previously failed to declare income should seriously examine the possibility of making a voluntary disclosure. This statement reflects the Minister’s position and does not replace an assessment of the individual case.
Tax Law Classification of Offshore Structures
Offshore companies are not impermissible merely because they are based in a low-tax jurisdiction. For tax purposes, however, key factors include whether income has been declared fully and correctly, who the beneficial owner is, and whether foreign companies or accounts had to be disclosed to the tax authorities.
Cross-border structures may involve various tax obligations. These include, in particular, filing obligations, duties to cooperate, and the correct attribution of income. If tax-relevant facts are declared incorrectly or incompletely, or are not disclosed in breach of a duty, this may have criminal law relevance under the conditions of § 370 AO (German Fiscal Code).
Whether an effective voluntary disclosure pursuant to § 371 AO (German Fiscal Code) can still be considered at all depends on numerous requirements and possible blocking grounds. A general assessment is not possible on the basis of the published information.
Significance for Companies, Investors and High-Net-Worth Individuals
The analysis of the data carrier shows that cross-border asset and ownership structures may increasingly become the subject of official scrutiny. This concerns not only persons directly resident in Germany, but also international structures with a connection to Germany.
For companies, investors and high-net-worth individuals, this may give rise to complex tax law issues, particularly in relation to shareholdings in foreign companies, trust or nominee arrangements, and the disclosure of beneficial ownership. MTR Legal Rechtsanwälte advises clients on tax law matters with an international dimension; further information can be found at Legal advice in tax law.
