[14] The earliest reported case on the rule is believed to be Attorney General v Lutwydge (1729) Bumb 280, 145 ER 674.
In 1775 Lord Mansfield CJ pronounced in Holman v Johnson (1775) 1 Cowp 341 at 343, 98 ER 1120 at 1121 that "no country ever takes notice of the revenue laws of another".
[17] In that case the House of Lords unanimously upheld the Court of Appeal (who had in turn unanimously upheld the trial judge) that the liquidator of an English company could not pay out sums to a foreign government because the tax claim was not justiciable in England.
[18]In Re State of Norway's Application (No 2) [1990] 1 AC 723 the Norwegian government sought assistance from the English courts in collecting evidence in relation to a tax claim.
Lord Goff said "It is of importance to observe that that rule is limited to cases of direct or indirect enforcement in this country of the revenue laws of a foreign state.
It is plain that the present case is not concerned with the direct enforcement of the revenue laws of the State of Norway.
In Milwaukee County v. M. E. White Co., 296 U.S. 268, 268 (1935) the Supreme Court was asked to consider whether revenue laws of other states should be enforced under the Full Faith and Credit Clause.
[1] The Supreme Court of Canada has upheld and applied the revenue rule in United States v. Harden [1963] SCR 366.
Professor Adrian Briggs of Oxford University has criticised it on the basis that it promotes the evasion of tax liabilities.
In Ben Nevis (Holdings) Limited v HMRC [2013] EWCA Civ 578 the English courts enforced a claim for South African taxes under a bilateral treaty between the countries.