Role of Deeming Fiction in Domestic Legislation vis-à-vis Tax Treaty - An Exposition by UK Supreme Court in Fowler’s Judgment - Sbs and Company LLP - Page 1 - 9 | Flip PDF Online

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Role of Deeming Fiction in Domestic Legislation vis-à-vis Tax Treaty - An Exposition by UK Supreme Court in Fowler’s Judgment

In a recent judgment of Fowler v. Her Majesty’s Revenue and Customs , the Supreme Court of United Kingdom had an occasion to deal with the role of deeming fiction in the domestic legislation and their applicability in the context of tax treaties. The said judgment elucidates certain important aspects which would have bearing on the international taxation. In this article, we would detail the facts, the reasonings and conclusions arrived by the Honourable Supreme Court of United Kingdom (UK SC) and also try to apply such principals to the Indian context to see the consequences arising thereof.

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Role of Deeming Fiction in Domestic Legislation vis-à-vis Tax Treaty - An Exposition by UK Supreme Court in Fowler’s Judgment