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

Those pleas were reiterated and particularised in Schedule 5B to the Particulars of Claim. Paragraph 3 of that Schedule alleged that Mr Shah procured or induced the Solo Model custodians to do the acts said to render them liable, and the same was said by paragraph 4 in respect of Syntax (from when it came under Mr Shah’s control). Those are allegations of accessory liability. Paragraph 4A of the Schedule alleged that Mr Shah “instructed or directed or procured” the Tax Agents to submit Solo Model tax refund claims containing the false representations alleged by SKAT, “as stated in paragraph 50(j) of the Particulars of Claim”. Paragraph 50(j) alleged that in connection with the Solo Model, the Tax Agents “acted on the instructions and at the direction of [Mr Shah] or his associates”. Paragraph 4A of the Schedule therefore did not raise any further or different case than that of Mr Shah being the Tax Agents’ “true principal” (as alleged in paragraph 57(b) of the Particulars of Claim).