What does a voluntary disclosure cost?
The costs of a voluntary disclosure (Selbstanzeige) consist of three blocks: the fee for the tax preparation work under the German Tax Advisors' Fees Regulation (Steuerberatervergütungsverordnung, StBVV), where applicable the support of a lawyer on the criminal law side, and the amounts that go to the tax authorities in any case — back taxes, interest on evaded taxes (Hinterziehungszinsen) under Section 235 of the German Fiscal Code (AO) and interest under Section 233a AO, plus, above €25,000 per offence, the surcharge under Section 398a AO.
Legal position as of: 9 September 2026
Fee for the tax preparation work
The basis is the German Tax Advisors' Fees Regulation (Steuerberatervergütungsverordnung, StBVV), the statutory fee schedule for tax advisors (Steuerberater). It is based on the value of the matter and the scope of the work — so the fee is not arbitrary, but follows a framework.
Within this framework, the actual effort is decisive, and it is determined by four factors:
Number of years concerned
Each year is a separate calculation and a separate amended declaration (Nacherklärung). Because of the deferred commencement (Anlaufhemmung), the period often goes back further than expected.
Number of accounts and wallets
Each source has to be obtained, checked and consolidated with the others. For crypto assets, this is the largest single item.
Data quality
A complete export is something different from an incomplete history that has to be reconstructed and estimated on a reasoned basis.
Scope of the amended declaration
One type of tax over a few years differs considerably from several types of tax over the full correction period.
Support from a lawyer
Not every voluntary disclosure needs the support of a lawyer (Rechtsanwalt). Under Section 392(1) AO, tax advisors may act as defence counsel in tax criminal proceedings where the tax authority conducts the proceedings independently — and that is the norm for voluntary disclosures and amended declarations.
It becomes necessary if the public prosecutor's office (Staatsanwaltschaft) takes over the proceedings, if charges are brought or if further offences are in question alongside the tax allegation. The lawyer's fees are then agreed separately and are not part of the tax advisor's fee.
How the roles are divided is explained on our page on tax criminal law.
What has to be paid in addition
These amounts arise regardless of who prepares the amended declaration. In most cases they are the larger part of the total.
- Payment of the back tax in full — this is not a penalty, but the tax that was owed from the outset.
- Interest on evaded taxes (Hinterziehungszinsen) under Section 235 AO.
- Interest under Section 233a AO.
If the understated tax exceeds €25,000 per offence, exemption from punishment under Section 371 AO does not apply. It is replaced by Section 398a AO: prosecution is dispensed with if the taxes and interest are paid on time and, in addition, a sum of money is paid to the state treasury.
The surcharge under Section 398a(1) no. 2 AO, staggered according to the amount evaded.
| Amount evaded | Surcharge |
|---|---|
| up to €100,000 | 10% |
| over €100,000 up to €1,000,000 | 15% |
| over €1,000,000 | 20% |
Two features of the surcharge are often overlooked: it is not refunded if the legal consequence does not ultimately occur. And the court can offset it against a criminal fine (Section 398a(4) AO) — it does not have to.
Why flat-rate figures are out of the question
We deliberately do not state any fee amounts on this page — no rates, no range and no fixed price, not even for an initial analysis.
The reason is not reticence, but meaningfulness. An amended declaration covering three years with complete reports and one covering ten years with reconstructed trading histories across several platforms differ many times over in the work involved. A figure on this page would be far too high for one case and far too low for the other — and in both cases worthless as a basis for a decision.
What we can commit to instead: an assessment of the scope before any costs are incurred, and a quote based on the StBVV.
How we prepare a quote
- 1
Recording the facts
Years concerned, types of tax, order of magnitude, number of accounts and wallets, state of the documents. Plus the question of whether there is time pressure from an impending exclusion ground (Sperrgrund).
- 2
Estimating the scope
This information shows how many amended declarations need to be prepared and how laborious the data preparation will be.
- 3
Quote before work begins
You receive a quote for the scope of the work before any costs are incurred. If the scope differs considerably during the work, we raise this with you before we continue.
Frequently asked questions about the costs
The questions we are asked most often about the fees and additional costs of a voluntary disclosure.
What does a voluntary disclosure cost?
The costs consist of three blocks. First, the fee for the tax preparation work, which is governed by the German Tax Advisors' Fees Regulation (StBVV) and depends on the effort involved. Second, if necessary, the support of a lawyer on the criminal law side. Third, the amounts that go to the tax authorities in any case: back taxes, interest on evaded taxes under Section 235 AO and interest under Section 233a AO — and, above €25,000 per offence, the surcharge under Section 398a AO.
Why do you not give a price range?
Because in this area it says nothing. The effort depends on the number of years concerned, the number of accounts, custody accounts and wallets, the state of the data and the scope of the amended declaration. A case covering three years with complete reports and one covering ten years across six trading platforms differ many times over. Any figure on this page would be too high for one and too low for the other.
What determines the fee?
The German Tax Advisors' Fees Regulation (StBVV), the statutory fee schedule for tax advisors. It is based on the value of the matter and the scope of the work. In practice, four factors are decisive: the number of years concerned, the number of accounts and wallets, the quality of the data and the scope of the amended declarations to be prepared.
What does the surcharge under Section 398a AO cost?
It is staggered according to the amount evaded: 10% up to €100,000, 15% above €100,000 up to €1,000,000 and 20% above that. The surcharge is not refunded if the legal consequence does not ultimately occur; the court can offset it against a criminal fine, but does not have to (Section 398a(4) AO).
How do we arrive at a binding quote?
In an initial consultation we record the facts: years concerned, types of tax, number of accounts and wallets, state of the documents. On this basis you receive a quote for the scope of the work before any costs are incurred. If it turns out during the work that the scope differs considerably, we raise this with you before we continue.
About the author
Maximilian Klein — Tax Advisor (Steuerberater) & Founder
Tax advisor (Steuerberater) specialising in amended declarations and voluntary disclosures.
Note: This page reflects the legal position as of 9 September 2026 and does not constitute advice on your individual case. Which amounts arise in a specific case depends on the specific documents and requires them to be reviewed.
Next step
Get the scope and costs assessed
One conversation is enough to narrow down the scope. You receive a quote before any costs are incurred.