Place of Effective Management: routine regional headquarters global policy functions alone do not establish subsidiary residency in India. Guidance clarifies that PoEM is presumed outside India if a company's board meetings are held mostly abroad, but PoEM will be in India if the board is effectively standing aside and management powers are exercised by a holding company or persons resident in India. Routine regional headquarters activities performed under general, group level global policy (payroll, accounting, HR, IT, supply chain, routine banking) do not by themselves constitute the board standing aside and will not establish PoEM for subsidiaries; GAAR may apply in cases of abusive tax planning.