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Thursday, May 21, 2026 · 27 days away
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Cum-Ex Trial Begins (Bonn, Germany)
Event overview
Pre-2012 Cum-Ex trades trial including ex-Macquarie banker; Europe's largest tax fraud case.
A former Macquarie Group banker is scheduled to stand trial in Bonn from 21 May 2026 in what German prosecutors describe as the largest tax-fraud case in European history. The Landgericht Bonn will hear charges tied to the cum-ex dividend-stripping schemes that drained an estimated €10 billion or more from European treasuries.
Cum-ex trades exploited a flaw in German capital-gains tax accounting between roughly 2005 and 2012, allowing coordinated buyers and sellers to claim the same dividend withholding tax refund more than once. The structure typically involved short-sellers, long-buyers and custodian banks executing synchronised trades around the dividend record date. Germany's Federal Court of Justice ruled in July 2021 (1 StR 519/20) that cum-ex constitutes criminal tax evasion, setting the legal frame for dozens of prosecutions centred on Cologne and Bonn. An EU-wide estimate by academic researcher Christoph Spengel put total treasury losses across Germany, Denmark, France, Italy, Belgium and Austria at above €150 billion when cum-cum variants are included.
Bloomberg reported on 17 April 2026 that Germany's highest court had rejected a final appeal and ordered the ex-Macquarie banker to face trial in Bonn on charges stemming from a 2011 scheme worth hundreds of millions of euros. Prosecutors in Cologne have led the national cum-ex effort since 2016, with lead investigator Anne Brorhilker overseeing more than 100 parallel probes before her resignation in April 2024 — a departure she publicly attributed to institutional resistance to prosecuting senior bankers. Several German and international banks — including Warburg, Maple Bank, HVB, Hypovereinsbank, and subsidiaries of Santander and Barclays — have settled or been convicted. Warburg repaid €176 million; Maple Bank collapsed in 2016 with a €450 million tax clawback.
Sanjay Shah, founder of Solo Capital and the central figure in the related Danish cum-ex case, was extradited from Dubai to Denmark in December 2023 and convicted in December 2024 to 12 years in prison.
21 May 2026 is the first hearing day set by the Landgericht Bonn after the Bundesgerichtshof's April 2026 ruling clearing procedural objections. The trial reopens the international dimension of the cum-ex scandal by focusing on an Anglo-Australian investment-bank trader, signalling that German prosecutors are reaching beyond domestic banks. A conviction would set precedent for additional foreign-national indictments already in preparation. The date also runs concurrently with the German statute of limitations cycle, which was extended to 25 years for serious tax evasion under the 2020 reform — meaning 2005-era transactions remain prosecutable only until late 2030.
Beyond the individual defendant, the trial puts pressure on remaining former Macquarie Group personnel who worked on the London-based structured-products desk during the relevant period. Civil-recovery actions by North Rhine-Westphalia and Hamburg tax authorities continue independently, seeking total refunds above €3 billion. The German banking sector's compliance posture is also in play: Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) has tightened its review of dividend-arbitrage trading, with reporting obligations under the 2022 tax-procedure amendment requiring daily position disclosure during dividend windows. Several pending German retail-investor class actions ride on the criminal-law findings.
Pair this with the Karlsruhe inheritance-tax ruling and the Berlin State Election 2026 for the 2026 German legal-political calendar. For cross-jurisdiction financial-crime coverage see the UK Post Office Horizon Vol 2 report.
When exactly does the trial begin? The first hearing is scheduled for 21 May 2026 at the Landgericht Bonn.
Is the trial confirmed or expected? Confirmed. The Bundesgerichtshof rejected the defendant's appeal on 17 April 2026, clearing the path for trial and binding the lower court's schedule.
Who is responsible for prosecuting? The Cologne public prosecutor's office (Staatsanwaltschaft Köln), which leads Germany's cum-ex investigations, with the Bonn regional court hearing the case under presiding judge assignments issued in early 2026.
Where can I read the official announcement? Landgericht Bonn press releases and the Cologne prosecutor's office publish docket-day statements; Bloomberg, Handelsblatt and Süddeutsche Zeitung carry daily court reports.
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