Place of Effective Management Indian Income Tax Perspective
11 Pages Posted: 2 Dec 2017
Date Written: November 20, 2017
'Place of effective management' (POEM) is an internationally recognized concept for determination of residence of a company incorporated in a foreign jurisdiction. Most of the tax treaties entered into by India recognise the concept of 'place of effective management' for determination of residence of a company as a tie-breaker rule for avoidance of double taxation. Many countries prefer the POEM test to be appropriate test for determination of residence of a company.
Keywords: Tax, International Tax, DTAA, Income Tax, Tax Residency, Corporate Residency, Tax Planning, Tax Structuring, GAAR, OECD Tax Convention, GAAR
Suggested Citation: Suggested Citation