CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2979 (Comm)

Mr Head KC also submitted rightly, in my view, that my findings that the primary respondents neither realised nor intended that the ‘Form + CAN’ tax refund applications with which they had any involvement would make to SKAT any of the representations it alleged, were quintessential factual findings with which it was fanciful to suppose that the Court of Appeal might interfere.

They involved a careful and thorough examination of all of the evidence, good and bad for SKAT and for each individual defendant.