CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2364 (Comm)

For multiple reasons, therefore, SKAT’s claims against Mr Shah for damages for deceit on the basis that he had a primary liability as a fraudster fail.

Furthermore, as I have just made clear in rejecting the ‘deliberate deceit scheme’ theory for primary liability, in my judgment there was no common design to which Mr Shah was party to trick SKAT into making payments by falsehoods in the tax reclaim documents. Therefore, the only accessory liability that might have fallen to be considered further, if SKAT had established that it was misled into paying Solo Model tax refund claims by misrepresentations in fact made to it through those documents, would have been the liability alleged by SKAT for inducing or procuring deceit.