Skatteforvaltningen (the Danish Customs and Tax Administration) (Respondent) v Solo Capital Partners LLP (in special administration) and others (Appellants)
8th November 2023
The United Kingdom Supreme Court has today unanimously and comprehensively upheld the Danish Tax Authority’s (SKAT) case that its €1.7billion claim to recover amounts wrongfully extracted from it by cum/ex fraudulent misrepresentations were not to recover tax in Skatteforvaltningen v Solo Capital Partners LLP and others [2023] UKSC 40: https://www.supremecourt.uk/cases/docs/uksc-2022-0066-judgment.pdf.
The claim does not therefore fall within the Revenue Rule, under which the courts will not enforce foreign tax laws.