On 24 March 2023, the UK High Court issued a preliminary ruling in a “Validity Trial”, awaiting the main trial, in the case brought by the Danish Tax and Customs Agency (SKAT) against Solo Capital Partners and others. SKAT has been attempting to recover EUR 1.7 billion in what it considers as unlawfully claimed and obtained refunds of Danish dividend withholding tax. Initially, the High Court rejected SKAT’s claims on the grounds that the Revenue Rule (or Dicey rule 3) barred English courts from entertaining claims involving the enforcement of a penal, revenue, or other public law of a foreign...