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

Mr Patterson did not participate in the Main Trial, and made some significant admissions as part of pleading guilty to criminal charges in Denmark and in a Response to a Notice to Admit Facts he served in these proceedings. They went as far as an admission that by the end of 2013, Mr Patterson considered that the Solo Model business was “wrong”. SKAT submitted, and conceded, that that admission did not go far enough. That was both submission and concession because it both encapsulated SKAT’s argument that Mr Patterson’s admissions understated the extent of his knowledge, and his intentions, during the relevant period, but also recognised (rightly) that a belief that in some unspecified way the Solo Model business was, or had become, “wrong”, did not found liability on any of the claims SKAT pleaded against Mr Patterson in these proceedings.