In Stichting Shell Pensioenfonds v Krys [2014] UKPC 41, the Privy Council has held that where a company was being wound up in a jurisdiction where it was incorporated, and where a foreign creditor had submitted a proof of debt to the liquidators, that creditor had submitted to the jurisdiction of the administering court, and could not bring proceedings in its own jurisdiction with the aim of obtaining priority over other creditors.