English Appellate Court Gives Partial Victory to Danish Tax Authority on Cum-Ex Case

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Friday, March 11, 2022
Author: 
Bruce Zagaris
Volume: 
38
Issue: 
3
Abstract: 

On February 25, 2022, the English Court of Appeal overturned a decision by the High Court[1] that the common law revenue prevents the Danish Revenue Authority (“SKAT”) from recovering withholding tax (“WHT”) refunds on the basis that refund claims were fraudulently made. [2]



[1]    SKAT v. Solo Capital [2021] EWHC 974.

[2]    SKAT v. Solo Capital [2022] EWCA 234.