As a rule, debts are situated where the debtor resides and hence where payment can be required (English, Scottish and Australian Bank Ltd v IR Commrs [1932] AC 238). A corporate debtor which carries on business in a number of countries is resident in all of them and accordingly the debt may be regarded as situated in each place where the corporation carries on business: New York Life Insurance Co v Public Trustee [1924] 2 Ch 101 per Atkin LJ at p. 120. It may be, however, that the document creating the debt specifies the place at which the obligation to pay is to be performed in which case the debt is situated there: Kwok v Commr of Estate Duty [1988] BTC 8,073.

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