From Beats to Bills: How DJs Tiësto and Afrojack Were Entangled in a $100M Offshore Tax Scheme

Spinning the Globe: When the Music Stops, the IRS Listens

Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto and Afrojack. But what most fans don’t see behind the pulsating beats and dazzling lights is a complex web of international income, tax obligations, and legal exposure.

Both Tiësto (real name Tijs Verwest) and Afrojack (real name Nick van de Wall) are global brands. They perform, produce, and earn across multiple countries. This means that their income is subject to multiple tax jurisdictions. Without careful planning, this can result in double taxation, excessive liability, or even unintentional legal trouble.

To legally and efficiently manage these global earnings, many artists and entrepreneurs explore offshore tax structures. These strategies aren’t about hiding money—they’re about smart, compliant financial engineering. However, as we’ll see, even tax professionals can misuse these tools, leading to serious legal consequences.

Offshore Tax Structures: What Are They, Really?

At their core, offshore tax structures are financial arrangements set up in jurisdictions outside of one’s home country.¹ These arrangements are often established in countries with favorable tax laws, commonly referred to as “tax havens,” such as Bermuda, the Cayman Islands, or the Netherlands Antilles.² Used correctly, these structures can help allocate income, protect assets, and reduce tax liabilities legally. The keyword here is “legally.” Offshore entities can allow income to be taxed at lower rates, defer taxation until the funds are brought back into a home country, or avoid taxation altogether if the income qualifies under specific exemptions or treaties.³

For entertainers like Tiësto and Afrojack, who earn royalties, appearance fees, and digital streaming income across multiple nations,⁴ these structures could streamline income reporting, avoid double taxation, and ensure compliance with international tax treaties.

It’s all about strategy: where is the income earned, who owns the rights to the intellectual property, and how are the contracts structured?

Dutch Tax Advisor Frank Butselaar and the Dark Side of Offshore Planning

Not all offshore planning is created equal—especially when the line between lawful structuring and criminal fraud is crossed. Frank Butselaar, once a respected tax attorney and former partner at international law firm Greenberg Traurig,⁵ became an unfortunate example of how sophisticated planning can turn deceptive as he advised global celebrities like DJs Tiësto and Afrojack on offshore strategies, earning him the nickname “the Taxman to the Stars” in the Dutch press.⁶ But rather than ensuring compliance, he orchestrated a fraudulent scheme that used shell companies and foreign trusts in jurisdictions like Cyprus and Guernsey to conceal over $100 million in income from tax authorities, listing friends and family as nominee beneficiaries while allowing the real clients to maintain control over the funds.⁷

The scheme spanned from 2012 to 2018, during which both Tiësto and Afrojack were temporarily living in the United States and thus subject to U.S. taxation on their worldwide income.⁸ Butselaar worked with a U.S. management firm to help ultra-high-net-worth clients, including DJs Tiësto and Afrojack and models Patricia van der Vliet and Daria Strokous, conceal millions in offshore income after they became U.S. tax residents.⁹ To execute the scheme, they used nominee owners (family members who lived outside the U.S.) to disguise control of offshore entities, while their celebrity clients secretly retained full access and benefit.¹⁰ Despite repeated warnings from U.S. tax attorneys and CPAs, Butselaar admitted to concealing over $70 million in offshore income for DJs Tiësto and Afrojack, including omitting overseas income from Afrojack’s 2013 U.S. tax return.¹¹

Ultimately, Butselaar pled guilty to a single count of aiding in the filing of a false tax return and was sentenced to 30 months in federal prison.¹² Having already served 21 months in pretrial detention in both Italy and the U.S., Butselaar is expected to be released soon, while the government seeks $19.25 million in restitution—a demand his attorneys contest, arguing he shouldn’t bear full responsibility since he wasn’t the taxpayer.¹³

This case is a reminder that even legitimate offshore structures can lead to serious legal trouble if they lack genuine purpose and transparency. Tax planning that ignores compliance isn’t just risky—it can cross the line into criminal conduct.

Smart Offshore Planning: A Legal Playbook for Global Earners

Let’s rewind. How could this have been done legally and ethically?

Offshore tax planning often gets a bad rap, but when done right, it’s a strategic and entirely legal way for global earners to manage complex income streams. Take a high-profile DJ like Tiësto, for example. By creating a parent company in the Netherlands to manage his intellectual property—think music rights, branding, and royalties—he could then license those rights to a subsidiary in Ireland. Ireland offers favorable corporate tax rates and strong IP protections, making it an ideal hub for receiving digital royalties from platforms like Spotify and Apple Music. Meanwhile, if Tiësto performs in the U.S., a U.S.-based entity could handle his performance income, subject to U.S. taxation but potentially reduced through tax treaties and deductions.

The key to this structure’s legality lies in its substance. Each entity must have a real business purpose, employees or contractors, actual bank accounts, and clearly documented transactions. This isn't about hiding income; it’s about allocating it wisely under international tax treaties and transfer pricing rules. When executed with integrity and transparency, this approach not only minimizes tax exposure but also reduces the risk of double taxation and boosts audit resilience. Unlike the flawed and fraudulent setups orchestrated by figures like Frank Butselaar, such legitimate planning steers well clear of legal landmines.

Ultimately, offshore doesn’t have to mean offshore scandal. It simply requires thoughtful customization based on where you live, where you earn, and what kind of income you generate. Whether you're a DJ, developer, or digital nomad, the principles remain the same: structure with precision, document with care, and consult the right experts. In a world where global income is the norm, smart offshore planning isn’t just legal—it’s essential.

From Risk to Strategy: Why Expert Guidance Makes All the Difference

The Tiësto and Afrojack case shows how even top global earners can fall into serious tax trouble without the proper guidance. Offshore tax planning can be a powerful tool, but only when handled with precision, legality, and care. At Fleurinord Law, our dual-licensed tax attorney-CPA crafts compliant, audit-ready strategies for individuals and businesses with international income. Whether you're managing global royalties or cross-border operations, don’t wait for a crisis to expose gaps in your global tax strategy—get ahead with expert, compliant planning from a licensed professional. Contact Fleurinord Law today to schedule a confidential consultation, and let’s turn complexity into clarity.

¹See Jane G. Gravelle, Reform of U.S. International Taxation: Alternatives, Cong. Rsch. Serv., RL34115, at 20–21 (2017), https://www.congress.gov/crs_external_products/RL/PDF/RL34115/RL34115.18.pdf (last visited May 8, 2025) (describing tax havens as jurisdictions used by nonresidents to reduce tax liability through investments and financial activities).

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³I.R.S., Offshore Income and Filing Information for Taxpayers with Offshore Accounts, FS-2014-07, at 1 (June 2014); U.S. Dep’t of the Treasury, The Deferral of Income Earned Through U.S. Controlled Foreign Corporations: A Policy Study, at 1–2 (Dec. 2000) (last visited May 8, 2025) (explaining that offshore entities can be used to legally defer U.S. taxation, reduce effective tax rates through foreign jurisdictions, or avoid taxation entirely under applicable exemptions or treaty provisions).

⁴Piya Sinha-Roy, Tiesto leads Forbes highest-paid DJs list with $22 million (Aug. 2, 2012), https://www.today.com/popculture/tiesto-leads-forbes-highest-paid-djs-list-22-million-wbna48472414 (last visited May 8, 2025) (reporting that Tiësto earned $22 million in one year through performances, endorsements, and music sales, making him the highest-paid DJ at the time); Katie Bain, Afrojack Signs to Universal Music Group as Part of New Dance Music Venture (Jul. 25, 2022), https://www.billboard.com/pro/afrojack-universal-music-group-new-dance-music-hub/ (last visited May 8, 2025) (reporting Afrojack’s partnership with UMG to develop and distribute EDM music globally, earning income from international royalties and digital streaming).

⁵Although Frank Butselaar referred to himself as a "tax lawyer," he is not a licensed attorney in any jurisdiction; he was, however, a shareholder at international law firm Greenberg Traurig's Amsterdam office up until 2013. See United States v. Butselaar, No. 7:22-cr-00560 (S.D.N.Y. sealed indictment filed Oct. 20, 2022).

⁶ Laura Italiano, How Tiesto's celebrity tax attorney hid $100M in income for his client list of millionaire DJs and models (Feb. 15, 2025), https://www.businessinsider.com/dj-tiestos-tax-attorney-sentenced-hid-income-2025-2 (last visited May 9, 2025).

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⁸See Butselaar Indictment, supra note 5; see also Press Release, U.S. Dep’t of Just., International Tax Advisor Arrested For Helping Conceal Over $100 Million In Income Of High-Net-Worth Taxpayers (Jul. 14, 2023), https://www.justice.gov/usao-sdny/pr/international-tax-advisor-arrested-helping-conceal-over-100-million-income-high-net (last visited May 9, 2025).

⁹See Press Release, U.S. Dep’t of Just., International Tax Advisor Pleads Guilty To Tax Fraud In Concert With U.S.-Based CPAs (Nov. 18, 2024), https://www.justice.gov/usao-sdny/pr/international-tax-advisor-pleads-guilty-tax-fraud-concert-us-based-cpas (last visited May 9, 2025).

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¹²Italiano, supra note 6.

¹³Italiano, supra note 6.