Sanjay Shah – The Cum-Ex Fraud That Cost Denmark £1 Billion
Den britisk-indiske finansmand bag Danmarks største skattesag nogensinde
Sanjay Shah, a British national of Indian descent, is the architect of the most extensive tax fraud case in Danish history. Operating from a luxury villa in Dubai, he built an international network of financial intermediaries between 2012 and 2015 that systematically manipulated the Danish system for dividend tax refunds. The scandal shook the Danish tax administration to its core and triggered a sweeping institutional overhaul: SKAT was subsequently restructured and split into Skatteforvaltningen and Gældsstyrelsen.
Cum-Ex is a financial scheme that exploits a loophole in the tax legislation of numerous countries relating to dividend payments on shares. The name derives from Latin: cum (with) and ex (without) — a reference to shares traded with and without dividend entitlement during the grey zone surrounding a dividend payment date.
In the Danish version of the scheme, Shah and his network filed claims for refunds of dividend tax that had never actually been paid to the Danish state. The mechanism worked by lending and trading shares at such speed and complexity that SKAT could not detect that the same block of shares was being used as the basis for multiple simultaneous refund claims. Every link in the chain — banks, stockbrokers, pension funds and shell companies — took a cut of the illegal proceeds.
Solo Capital and the Network Behind the Fraud
