Skatteforvaltningen v Solo Capital Partners LLP  EWCA Civ 234
1st March 2022
The Court of Appeal has unanimously upheld the Danish Tax Administration’s appeal that the Revenue Rule does not apply to claims for recovery of amounts paid as a result of allegedly false withholding tax refund claims made by non-shareholders who received no dividends. The Revenue Rule prevents the enforcement of foreign revenue law.
Jonathan Schwarz was part of the Danish Tax Administration (SKAT)’s counsel team lead by Lord Pannick QC.
Skatteforvaltningen v Solo Capital Partners LLP  EWCA Civ 234: http://www.bailii.org/ew/cases/EWCA/Civ/2022/234.html