Yeah, I know it might sound a bit far fetched but let's just wait and see....
The FISC in France had a go at both RY and U2 a few years ago and it was all more or less over and done with within a couple of months and they were brought into the tax net - both staff and companies. How deeply into it, I'm not sure, but deep enough to the FISC's satisfaction.
It really shouldn't need a couple of years for the BZSt to achieve the same result unless they were 'reminded' to get on with it....