Focus offshore: NRW buys extensive tax data on international tax havens

According to recent press reports from December 11, 2025, the state of North Rhine-Westphalia has purchased an extensive data set with tax-relevant information from international offshore and low-tax jurisdictions via the State Office for Combating Financial Crime (LBF NRW). The dataset comprises more than one terabyte and contains customer information from service providers based in the United Arab Emirates, the Cayman Islands, Panama, Hong Kong, Singapore, Mauritius and Cyprus, among others.

The data is intended to provide indications of assets and income that may have been concealed from the German tax authorities. According to the authorities, the information is considered to be very valuable and is currently being evaluated.

This means that the North Rhine-Westphalian tax authorities may have data on German taxpayers who have not or not fully declared tax-relevant matters with a foreign connection. In particular, the purchased data may contain indications of undeclared income in connection with foreign assets or tax-relevant transfers of assets abroad. Even a formal relocation abroad does not necessarily rule out a tax liability in Germany.

Status quo and possible consequences of data purchase

The data is currently being examined by the LBF NRW and will probably be compared with existing tax data. It is to be expected that the information – as in previous cases of tax CD purchases – will be systematically evaluated and forwarded to the responsible tax offices and tax investigation offices.

If the corresponding income or assets have not yet been properly declared, there is a considerable risk of criminal tax proceedings being initiated. In addition to additional tax payments, there is a risk of interest and fines or imprisonment.

How taxpayers should act now

There is an acute need for action for taxpayers with previously undeclared offshore matters. Previous experience with tax CDs shows that the tax authorities are able to efficiently evaluate even extensive mass data.

The current publications can therefore be seen as an indication of increased audit activity by the tax authorities. Previously undeclared tax matters should be reviewed immediately and – if necessary – subsequently reported. Such a subsequent declaration should generally be structured in such a way that it fulfills the strict formal requirements of a voluntary disclosure exempting the taxpayer from penalties and fines.

The requirements for an effective voluntary disclosure are usually complex in such cases, so that support from specialized advisors is recommended. As long as the tax authorities have not yet discovered the offense, it may still be possible in principle to make a voluntary disclosure with exemption from prosecution. However, as the evaluation of the data progresses, the risk of a blocking effect and thus ineffectiveness of the voluntary disclosure increases considerably. However, even if a crime has already been discovered in an individual case, a delayed voluntary disclosure can in practice lead to considerable reductions in penalties or even the termination of the investigation proceedings.

KPMG Law has a nationwide team of specialized criminal tax lawyers with many years of experience, including in cross-border matters and voluntary disclosures of foreign assets. We are happy to support you at short notice in the development and implementation of a suitable preventive protection and defense strategy.