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

SKAT advanced an allied submission that because Mr Patterson surely knew (and indeed I would have been content to find, on the probabilities, that he did know) that the Solo Model settlement method was a share-less method in which, at settlement, the buyer’s stock loan fed the stock lender’s stock loan which fed the short seller’s sale, so that there was no (external) shareholding or dividend income, he “must therefore also have known that the Solo Applications were based on fraudulent documentation”. I do not accept that argument. It was not self-evident that the only way to cause SKAT to pay tax refund claims was to make statements to it that Mr Patterson would have known to be false, from his knowledge of how the Solo Model worked.