Search results with tag "Place of effective management"
Overview of Double Tax Avoidance Agreements (‘DTAA ...
www.wirc-icai.orgPlace of Effective Management (‘POEM’) is situated. OECD Commentary says: • Place where key management and commercial decisions that are necessary for conduct of business are in substance made • An entity may have more than one place of management, but it can have only one POEM. FOR INDIVIDUALS. RULE 3. National.
Place of Effective Management - International taxation
www.fitindia.org'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 recognize the concept of 'place of effective management' for determination of residence of a …
Place of Effective Management (POEM) - Rashmin Sanghvi
www.rashminsanghvi.com4.1 Effective management: The words Effective Management refer to actual management and not just formal or ostensible management. For example, in some SPVs, the consultants may be the directors. One consultant/ solicitor/ banker may be managing a thousand companies. The clerical staff of this …