SKAT v Solo Capital Partners [2023] EWHC 590 (Comm)
24th March 2023
On 24 March 2023, the High Court handed down judgment in the case of SKAT v Solo Capital Partners [2023] EWHC 590 (Comm). Following a 4-week trial, Mr Justice Andrew Baker comprehensively upheld the Danish Tax Administration’s exposition of the taxation of dividends in Denmark, the operation of tax treaties in relation to those dividends as well as related securities law and market practice. The judgement is an important milestone in SKAT’s actions to recover €1.7 billion lost through cum/ex fraud.
Jonathan Schwarz was tax counsel for SKAT as part of a team lead by Charles Graham KC and Jamie Goldsmith KC, instructed by Pinsent Masons.
The decision can be read here.
http://www.bailii.org/ew/cases/EWHC/Comm/2023/590.html
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