On 23 October 2017, India's Central Board of Direct Taxes issued Circular No. 25 of 2017, which clarifies the application of the place of effective management (POEM) determination guidelines in the case of a regional headquarters structure where employees working in India have responsibility or oversight over the operations in other countries of the region. The POEM guidelines were issued in January 2017 as Circular No. 06 of 2017 and are used in relation to the determination of residence in…