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

Mr Horn admitted knowing at the time that the purpose of a tax refund claim was “to seek a refund of (a) tax withheld; (b) on dividends that had been received; (c) on shares owned by the [named client]”, that a tax refund claim “could not be made without submitting these “matters” to SKAT (i.e. that there had been tax withheld on dividends received on shares owned by the [client])”, and that a CAN was a statement by a custodian “which set out “facts” regarding the client’s receipt of a dividend on a particular stock, whose primary purpose was to support a tax reclaim”; and

“These matters constitute the essence of the Core Representations.”