On 24 January 2017, India's Central Board of Direct Taxes issued Circular No. 06 of 2017, which provides final guidelines for the determination of the place of effective management (POEM) of a company. The guidelines are in relation to India's rules for the determination of residence, which were changed as part of Finance Act, 2015 and made effective 1 April 2017 by Finance Act, 2016.
Under the prior rules, residence of a company was determined based on whether the control and management of …