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

SKAT alleged that Mr Patterson was liable on the basis of assistance pursuant to a common design to deceive SKAT. Until oral closing argument, SKAT had suggested that participation in Sanjay Shah’s acquisition of control of Varengold Bank and Dero Bank “assisted in the concealment or laundering of the proceeds of fraud [which] assisted the commission of the tort of deceit by making it harder for SKAT to recover such proceeds and … recoup its losses [and] also contributed to SKAT not discovering the fraud earlier and therefore paying out further tax reclaims on a false basis … .” That suggestion was withdrawn by SKAT in oral closing argument, so I say nothing more about it here (or in later sections of this Appendix – it was also raised, but dropped in oral closing argument, against various other trial defendants). In the case of Mr Patterson, there was never any need to rely on the Varengold Bank and Dero Bank episodes to establish more than minimal assistance in Solo Model trading with a view, as Mr Patterson appreciated, to tax refund claims being submitted by the Tax Agents on behalf of the Solo Model USPFs and LabCos. Without doubt Mr Patterson provided such assistance.