German tax law gives immunity from punishment to a tax evader who corrects his tax returns in a Selbstanzeige, a self-disclosure. The immunity does not apply if the offense had already been discovered, in whole or in part, at that time, and the offender knew this or should have expected it (§ 371 AO). On 15 January 2013, his bank called Uli Hoeneß, the president of Bayern Munich, after a reporter from the magazine Stern had been asking questions at the bank.
Early on 17 January 2013 he filed a self-disclosure. The tax office found that it was not a vollständige und einwandfreie Selbstanzeige, a complete and correct self-disclosure, and the court ruled it invalid. He was sentenced to three years and six months in prison for evading 28.5 million euros in tax. Hoeneß had said he filed on 12 January. That date later turned out to be untrue.