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SKAT and the revenue rule

The ‘revenue rule’ is a longstanding legal principle that the courts of one country will not enforce the tax laws of another country. It was recently tested in the High Court, as David Corker and Claire Cross (Corker Binning) report.

The juggernaut case of Skattenforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners & others [2021] EWHC 974 (Comm) (‘the proceedings’) came to an abrupt halt in April of this year courtesy of Dicey’s ‘rule 3’.

Dicey’s rule 3 also known as the revenue rule in respect of tax matters prevents a sovereign state from suing in a foreign court for taxes owed to it.

Cum ex

The background to the Danish tax authority’s High Court litigation was the high profile cum ex scandal which has caused outrage on the continent. Cum ex was a trading strategy based on selling shares and claiming...

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