Cum-Ex Investigations

“Kingsley Napley LLP has carved out a niche in criminal tax investigations and litigation, drawing on broad expertise in corporate criminal defence to advise clients on the spectrum of tax fraud cases."

Legal 500 UK 2020

‘Cum-Ex’ is the description given to a method of trading certain types of shares around the dividend record date which allows more than one participant to claim a tax rebate in respect of the same dividend payment.

Prevalent in Germany but also other EU countries such as Denmark, Belgium, and France, the scheme has been the subject of much debate since the issue came to the attention of the mainstream media. The loss to the German tax authorities alone as a consequence of Cum-Ex trading is said to be in excess of €55 billion and the scale of this alleged loss and the cross-border nature of the trading chains means that there are now many regulatory and criminal investigations being undertaken across Europe. German prosecutors have charged numerous individuals with tax evasion and in March two former London-based investment bankers were convicted in the first ever criminal trial for Cum-Ex trading. 

The UK’s Financial Conduct Authority (the FCA) has also confirmed that it is investigating a number of financial institutions and individuals over conduct in London’s financial markets which may have supported Cum-Ex trades executed in other EU countries.

How we can help

Kingsley Napley’s leading team of lawyers have advised on Cum-Ex cases and have extensive experience of complex financial services investigations and tax investigations spanning different jurisdictions - including the US. We are able to offer the breadth of knowledge that these cases require; an individual or business at risk of an investigation for involvement in Cum-Ex trading will need to consider any obligations to their regulators and if there is a need for an internal investigation as well as the risk of dawn raids on offices and homes, account freezing orders, mutual legal assistance and even extradition proceedings.

Please contact us if you would like more information on how we can assist.

Recent Cases

  • Advising a company in respect of Cum-Ex investigations in several European jurisdictions.
  • Advising a former financial services professional, who is under criminal investigation in relation to Cum-Ex tax evasion.
  • Acting for a hedge fund and Director in cross-border tax fraud investigation relating to Cum-Ex.
  • Advising a bank employee in internal investigation relating to CumEx.


What clients and directories have said about us

Deep bench of experienced lawyers with an approachable style.”

Legal 500 UK 2021

Regarded as one of the best financial crime firms."

Chambers High Net Worth Guide 2020

They're one of the firms that is right at the top of the scale. They're very experienced in handling the big cases. They're extremely well resourced and I've never had anything other than a good experience with them."

Chambers UK 2020 – A Client’s Guide to the UK Legal Profession 


Excellent white-collar crime and fraud firm covering all key UK regulators.”

Legal 500 UK 2021

A premier outfit for individuals under regulatory investigations."

Chambers UK 2021

The firm is well known as a blue-chip firm for white-collar crime that represent individuals investigated for tax fraud also.”

Legal 500 UK 2021

Bright and dedicated lawyers."

Chambers UK 2021



When an individual or company is faced with a criminal or regulatory investigation we manage every step of the process.

Tax Investigations

A tax investigation by Her Majesty’s Revenue and Customs (HMRC) could have serious implications for you and your business.

Internal Investigations

Corporate clients require sophisticated and sensitive advice when they encounter internal crises which have the potential to escalate.

FCA Investigations

Our team of expert lawyers has an impressive track record of successfully defending both individuals and institutions facing regulatory misconduct, disciplinary breach and criminal investigations conducted by the FCA.

Financial Services Investigations

We provide intelligent and tactical representation to those involved in an investigation by defending accusations and mitigating risks.

Dawn Raids, Search and Seizure

When subject to a “Dawn Raid”, search and seizure operation and search order you require timely advice. Our specialist lawyers can provide the assistance you require.

Account Freezing and Forfeiture Orders, and Cash Seizure

Tackling illicit finance and the proceeds of crime is a government priority and law enforcement focus.


Kingsley Napley has a wealth of experience in successfully defending extradition requests having worked in this field for several decades.

Mutual Legal Assistance

Robustly defending requests from foreign jurisdictions is not for the faint-hearted or inexperienced. Our lawyers are recognised leaders in the field.


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