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

Mr Horn is evidently clever, articulate and knowledgeable. In my judgment, his evidence on significant contentious matters was not straightforward factual testimony. Rather, in my view, he was advancing carefully constructed attempts to explain what went on in a way that might persuade the court to find that nothing at all untoward occurred, and that he had a seriously researched, reasonable belief at the time that the Solo Model and Maple Point Model trading in fact generated Danish dividend tax refund entitlements. Although Mr Horn’s evidence was more measured and coherent than Sanjay Shah’s, inevitably it came unstuck on numerous points because so many aspects of those schemes just cannot be spun innocently as Mr Horn was trying to spin them. The result is that I assessed Mr Horn to be generally untrustworthy as a witness on contentious matters of fact.