Clark (Inspector of Taxes) v. Oceanic Contractors Inc.

Abstract

Jurisdiction — Territorial — Presumption against extraterritorial application of legislation — Tax legislation — Scheme for the collection of income tax in respect of employment income — Employer required to deduct amounts due in respect of tax from payments to employees — Whether scheme applicable to foreign corporation employing persons to work in areas within State’s continental shelf — Employees liable to income tax — Whether collection scheme automatically applicable if employees liable to income tax — Notion of corporation’s tax presence within State — Income and Corporation Taxes Act 1970Sea — Continental shelf — Status — Whether United Kingdom continental shelf part of the United Kingdom — Continental Shelf Act 1964 — Tax liability of foreign corporation operating on continental shelf — The law of England