Robert Stewart was living and domiciled in Ireland. However, in 2007 and 2008, he carried out a series of transactions with a French bank to acquire shares in a publicly listed French business. In total, he drew down €7.4 million from Société Générale over those two years, to acquire stock in the French energy and utilities giant Veolia. In addition to the shares purchased, he also received further shares issued by the company by way of a scrip dividend, where the company issued new shares to existing shareholders. At various times, the Irish-based investor held more than 400,000 shares in…

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