Penningtons Manches Cooper acts in landmark SKAT litigation

Posted: 06/10/2025

Penningtons Manches Cooper partner Richard Marshall, supported by managing associate Oliver Cooke and associate Charlotte Allan, successfully represented individual defendants John Devonshire and Alexander Koerner in one of the most significant civil fraud cases ever heard in the UK — Skatteforvaltningen v Solo Capital Partners & Others — brought by the Danish tax authority SKAT.
 
The case centred on alleged fraudulent claims for dividend tax refunds totalling approximately £1.4 billion. It involved 106 defendants and culminated in a 138-day trial in the Commercial Court, the longest ever listed hearing in the history of the UK Commercial Court.
 
The lead defendant was Solo Capital Partners, a hedge fund formerly operated by renowned trader Sanjay Shah, who was convicted in Denmark in a related criminal trial. SKAT alleged that Shah and others orchestrated a complex 'cum-ex' trading scheme to exploit weaknesses in Denmark’s tax system.
 
In a 326-page judgment, handed down on 2 October 2025, Mr Justice Andrew Baker dismissed SKAT’s contested claims. While the court accepted that the tax refund claims were invalid under Danish law, it found that SKAT had not been deceived into paying them. 

This decision sets a significant precedent in cross-border fraud and tax recovery claims. It has been described as perhaps the largest and most complicated civil proceedings ever commenced in the commercial court.
 
Penningtons Manches Cooper instructed leading counsel Hugh Jory KC of 4 New Square in the matter. The firm's involvement in the case underscores its expertise in complex, high-value international disputes.
 
Richard Marshall commented: "This was a hugely complex matter, and we are pleased to have successfully represented our respective clients, who have been vindicated by this judgment. This was very much a team effort and the culmination of work we commenced on defending SKAT's claims some five years ago."

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