Clark v. Oceanic Contractors Inc., [1982] BTC 417, [1983] 1 All E.R. 133 (HL)

nS.204(1) of the Income and Corporation Taxes Act 1970 stated baldly that "income tax shall ... be deducted or repaid by the person making payment" without (like s. 153(1) of the Canadian Act) stating explicitly that the payor, to be subject to this withholding obligation, must be a resident of or carrying on business in the jurisdiction. An argument was rejected that this provision, regarding collection of tax by deduction from wages, could never have been intended to apply to a foreign company, non-resident in the United Kingdom, which made payments outside the United Kingdom. It was sufficient that the payor carried on a trade in the United Kingdom to make it subject to the provision.

"[U]nless the contrary is expressly enacted or so plainly implied that the courts must give effect to it, United Kingdom legislation is applicable only to British subjects or to foreigners who by coming to the United Kingdom, whether for a short or a long time, have made themselves subject to British jurisdiction."