After checking all the P38 holsters online at GB and eB, not one of them is like this one.
All the P38 holsters either have the closure strap pointing downwards and passing thru a metal stirrup, or are the soft type with the double-flapped opening face, or they are like the later Bundeswehr holsters with the strap facing upwards and held by a leather stirrup and a stud, but having the flat flexible top flap with the internal belt loops.
I'm still puzzled, but I like the holster better than my Bundeswehr one.
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