An offshore perspective: the English Commercial Court’s decision in the SKAT “cum-ex” case and Dicey Rule 3
In April this year, Mr Justice Baker of the English Commercial Court dismissed proceedings brought by the Danish national tax authority (SKAT) against over 100 defendants in connection with more than DKK2.5 billion in tax refunds that SKAT alleged it had been induced to repay by misrepresentations: Skatteforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners LLP (in special administration) and others [2021] EWHC 974 (Comm).