Place of Effective Management Indian Income Tax Perspective

11 Pages Posted: 2 Dec 2017

See all articles by Arkodeb Sinha

Arkodeb Sinha

Independent; A.Sinha & Associates, Advocates

Date Written: November 20, 2017

Abstract

'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

Sinha, Arkodeb, Place of Effective Management Indian Income Tax Perspective (November 20, 2017). Available at SSRN: https://ssrn.com/abstract=3074254 or http://dx.doi.org/10.2139/ssrn.3074254

Arkodeb Sinha (Contact Author)

Independent ( email )

No Address Available

A.Sinha & Associates, Advocates ( email )

3A, Garstin Place, 6th Floor
Kolkata, 700001
India

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