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

For current purposes, the important implication of Mr Bains’ presentation to Arunvill, in my judgment, is that it contradicts the idea that Mr Bains thought when working for Sanjay Shah that the Solo Model tax refund claims amounted to or involved fraud on SKAT. In saying that, to be clear, I consider that Mr Bains would have understood that it would be fraud deliberately to cause tax refund claims to be submitted that made false statements to SKAT designed to mislead it into paying out. I find that Mr Bains did not understand that the Solo Model involved that, or consider it as a possibility prior to receiving Arunvill’s reaction. I was unimpressed by Mr Bains in a number of respects, but I think it inconceivable that he took to Arunvill, having trailed it to them as the big money-making idea he would bring, a scheme to defraud national tax authorities, believing it to be such and envisaging that they would be happy to replicate it.