Deutsche Bank has once again found itself in the crosshairs of German tax authorities, as tax inspectors carried out a surprise raid on the headquarters of the banking giant in Frankfurt. This new operation is linked to the massive "cum-cum" style tax fraud scandal surrounding dividend payments. It is a controversial "trick" that flourished during the financial crisis and is estimated to have cost state coffers billions of euros. The alleged roles of German financial firms in these transactions, as well as in related cum-ex deals, are likely to cost the industry approximately 7 billion euros ($8 billion), the German financial supervisor BaFin stated last week, citing an investigation.
Investigators from the Prosecutor’s Office and the Tax Authority have been conducting searches since Wednesday morning (22/7/2026) at the headquarters of the German banking giant in Frankfurt. According to information from "Business Insider" and WELT, these measures are connected to investigations into suspected tax evasion in relation to "cum-cum" transactions. Journalists from "Business Insider" and WELT are on site and were able to observe several groups of individuals gaining access to the building.
According to Handelsblatt, approximately 70 investigators conducted a search on Wednesday morning (22/7/2026) at the headquarters of Germany's largest banking institution in Frankfurt. As Handelsblatt also reports, the raid is connected to investigations by the Düsseldorf Prosecutor’s Office regarding so-called "cum-cum" transactions. Deutsche Bank confirmed the raid and stated: “Deutsche Bank is being investigated as a third party and the bank is fully cooperating with the authorities.”
Specifically, these involve transactions processed by Deutsche Bank subsidiary, Postbank, with a British investment bank. According to information, these transactions took place between 2008 and 2010. The term "cum-cum" describes stock transactions around the dividend payment date, during which various domestic and foreign market participants attempted, through the temporary transfer of shares, to reduce the burden of capital gains tax.
Unlike "cum-ex" transactions, they did not aim for multiple refunds of the tax on dividends. However, courts and investigative authorities have been evaluating such schemes increasingly strictly in recent years and are examining them in numerous cases. Such deals are under scrutiny from both a tax perspective and a criminal perspective.
As reported by the newspaper Süddeutsche Zeitung, the list of defendants includes ten former top executives of Postbank. Among them is said to be a banker who, two years ago, managed to rise to the top executive ranks of Deutsche Bank. It is noted that Deutsche Bank is affected indirectly, as it acquired Postbank in 2019.
The dividend “trick”
At the center of the investigations are two complex methods of tax avoidance and fraud that flourished during the financial crisis, depriving state coffers of billions of euros. In cum-cum transactions, foreign investors temporarily transferred shares of German companies to domestic banks shortly before the payment of dividends. In this way, they avoided the capital gains tax withholding that applied to foreign shareholders. Once the dividend was collected without the tax burden, the shares were returned to their original owners, with banks keeping a generous commission.
Although initially presented as "legal" tax planning, judicial authorities now consider it coordinated tax evasion. On the other hand, cum-ex constituted a much more aggressive and blatantly criminal practice. Through rapid, cross-border trades of shares around the dividend date, those involved "confused" the banking system, creating fictitious tax payment certificates. Thus, they managed to collect tax refunds from the state that had never actually been paid.
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