David H. Rosenbloom. Taxing the Income of Foreign Controlled Corporations. 36 Brooklyn Journal of International Law 1525, 1532. 2001.

Ex parte Blain; In re Sawers (1879) LR 12 Chancery Division 522 at 526.

Clark (Inspector of Taxes) v. Oceanic Contractors Inc. (1983) 1 ALL ER 133.

Clark v. Oceanic Contractors Inc. (1983) Lord Scarman: «Parliament recognises the almost universally accepted principle that fiscal legislation is not enforceable outside the limits of the territorial sovereignty of the Kingdom. Fiscal legislation is no doubt drafted in the knowledge that it is the practice of nations not to enforce the fiscal legislation of other nations. But, in the absence of any clear indications to the contrary it does not necessarily follow that Parliament has in its fiscal legislation intended any limitation other than that imposed by such unenforceability».