Final notification by CBDT for taxation of foreign Cos held as resident in India as per Place of Effective Management

The much awaited Notification on Place of Effective Management (POEM) guidelines is released and attached herewith for your reference. You would recall that the draft notification was issued  in June last year and we had been requesting for the release of final notification considering the rules become effective from FY 16-17. The notification is deemed to have come into force retrospectively from April 1, 2017.  


While we had raised several ambiguities some have been partially addressed and for the rest we will continue to engage with the Government basis the feedback received from industry.


Also attached is a summary of key relevant provision along with a comparison of draft and final notification and issues addressed basis NASSCOM recommendations.

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