https://www.taxtmi.com/manuals?id=1880 POEM determination requires a two stage primary factor test: identify who actually makes the company's key management and commercial decisions and determine where those decisions are in fact made. Relevant indicators include the substance and location of board and executive committee decision making, the head office and senior management base, habitual residence of decision makers when remote decision making is possible, and the locus of persons exercising authority through circular resolutions. If primary factors are inconclusive, secondary factors such as the place of main activities or where accounting records are kept may be considered. en-us Fri, 06 Jan 2023 11:41:00 +0530 Mon, 16 Mar 2026 17:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=1880 POEM determination requires a two stage primary factor test: identify who actually makes the company's key management and commercial decisions and determine where those decisions are in fact made. Relevant indicators include the substance and location of board and executive committee decision making, the head office and senior management base, habitual residence of decision makers when remote decision making is possible, and the locus of persons exercising authority through circular resolutions. If primary factors are inconclusive, secondary factors such as the place of main activities or where accounting records are kept may be considered. Manuals Income Tax Fri, 06 Jan 2023 11:41:00 +0530 https://www.taxtmi.com/manuals?id=1880