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

SKAT’s submission was a single sentence, relying on Mr Shah’s admission in cross-examination, for each form of Solo Model CAN, that anyone reading the CAN would think that the issuer of the CAN honestly believed the statements in it were accurate and true. That does not prove appreciation of the honest custodian representation, which would require an understanding that the Tax Agent was stating to SKAT that the custodian had acted honestly; indeed, more specifically, that the Tax Agent was stating to SKAT that the custodian honestly believed the core representations to have been made by the CAN and to be true.