- Landmark dismissal of £1.5bn claim by the Kingdom of Denmark (Skatteforvaltningen (Danish Customs and Tax Administration) v Solo Capital Partners LLP (in special administration)
- What was the background?
- What did the court decide?
- Case details
Dispute Resolution analysis: in what is understood to be the first occasion, the application of Dicey’s Rule 3 to tax refunds has arisen for definitive determination. The High Court dismissed a £1.5bn claim by the Kingdom of Denmark (acting via its national tax authority, Skatteforvaltningen) arising from an alleged cum-ex (withholding tax reclaim) tax fraud said to have taken place between 2012 and 2015. Adam Zellick QC and Ian Bergson of Fountain Court Chambers discuss the case. The claim has been described by Mr Justices Andrew Baker and Foxton respectively as ’litigation on a massive scale’ and ’one of the largest and most complex pieces of litigation to be heard in the Commercial Court’. It involved more than a hundred defendants and over 20 separate legal teams and has been ongoing for nearly three years.
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