are simply tax avoidance or evasion dressed up by the Danish authorities as complex criminal frauds.

We accept and emphasise that the Courts of the Isle of Man do not act as tax collectors for foreign jurisdictions. However there is no rule of law inhibiting the Attorney General from giving assistance to foreign jurisdictions pursuant to Section 24. The bearing of tax laws on alleged frauds may well be a relevant consideration for the Attorney General, but his hands ought not to be tied one way or the other. He may regard an alleged complex fraud as in reality tax collection dressed up, or he may have regard to tax laws which are harsh or for breach of which the death penalty is enforced. All these may well be relevant considerations but there is nothing in the Act which forbids the Attorney General from giving assistance pursuant to Section 24 merely because the basis of the alleged crimes is fiscal.

For the avoidance of doubt this decision relates to all the powers of the Attorney General granted by Section 24

BENET HYTNER Q.C.