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

Ms Rømer was the head of Accounting II, the section of SKAT’s Accounting Department concerned with dividend tax, from 2009 until her retirement on 1 December 2013. She had a good working knowledge of the function performed by Mr Nielsen, who reported indirectly to her; but she had no responsibility at any time either for carrying out that function or for deciding that it should be as limited as it was. I found her feisty, argumentative and defensive, and I was not comfortable that she gave evidence motivated simply by a desire to relate what she believes she remembers of contemporaneous events or matters of which she has or would ever have had first-hand knowledge or understanding. Rather, it seemed to me, she focused primarily on trying to work out where questions were going, so as to give, if she could, answers she thought would be helpful to SKAT’s case, or exculpatory of blame for her or her team in relation to what has been a significant public scandal in Denmark. She made some important concessions that were inevitable in the face of the contemporaneous documents. Without saying that her evidence was wholly unsatisfactory, I do not consider that Ms Rømer gave what I can regard as generally trustworthy testimony.