Skatteforvaltningen v Solo Capital Partners LLP & Ors

Skatteforvaltningen v Solo Capital Partners LLP & Ors

Permission to appeal was refused because SKAT's proposed grounds were either factual findings not susceptible to appellate interference, legal points already decided correctly, or claims that failed for logically prior reasons. There was no realistic prospect of success nor any compelling reason to grant permission to appeal.

Parties
Claimant: SKATTEFORVALTNINGEN (the Danish Customs and Tax Administration); Defendants: SOLO CAPITAL PARTNERS LLP (in special administration) and many others
Jurisdiction
England and Wales
Judgment Date
14 November 2025
Procedural Posture
Commercial Claim / Application for Permission to Appeal After Trial Judgment
Outcome
Permission to appeal refused
Legal Topics
Permission to Appeal, Deceit, Unjust Enrichment, Proprietary Remedies, Constructive Trust, Tracing, Misrepresentation
Civil Procedure Commercial Law Fraud Permission to Appeal Deceit Unjust Enrichment Proprietary Remedies Constructive Trust +2 more

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Parties

SKATTEFORVALTNINGEN (the Danish Customs and Tax Administration)

Claimant

SOLO CAPITAL PARTNERS LLP (in special administration) and many others

Defendants

Procedural Posture

Commercial Claim / Application for Permission to Appeal After Trial Judgment

Legal Issues

  1. 1 Whether SKAT was entitled to permission to appeal dismissal of claims for deceit, unjust enrichment, and proprietary remedies
  2. 2 Whether representations alleged by SKAT were made by tax refund documents
  3. 3 Whether SKAT was induced by alleged representations to make payments

Ratio Decidendi

Permission to appeal was refused because SKAT's proposed grounds were either factual findings not susceptible to appellate interference, legal points already decided correctly, or claims that failed for logically prior reasons. There was no realistic prospect of success nor any compelling reason to grant permission to appeal.

Court Disposition

Permission to appeal refused

Orders

  • SKAT's application for permission to appeal is dismissed
  • No permission to appeal granted on any ground