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

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

Fecha: 02-Oct-2025

That came nowhere close to an admission by Mr Horn that he understood and intended at the time that something to the essential effect of the tax ownership representation, as pleaded, would be made to

150.

That came nowhere close to an admission by Mr Horn that he understood and intended at the time that something to the essential effect of the tax ownership representation, as pleaded, would be made to SKAT. Moreover, that evidence only justified SKAT’s claim that Mr Horn admitted the making by the CAN of “a statement about the number of shares held [in a] custody account” if that means something other than, and falling well short of, a real shareholding (a ‘settled balance’ of shares). That is because the follow-up questions explored what Mr Horn meant by the acceptance in his initial answer that the CAN recorded a ‘number of shares’ that were ‘held in the custody account’. His further answers made clear that he had not meant, and did not admit, that the CAN recorded any actual shareholding.