Tata Sons - Treaty residence
Facts
Treaty residence claim of a Mauritius-based group entity.
Issue
Place of Effective Management (POEM) determination post-2017.
Held
POEM determination is a fact-specific inquiry; board-meeting location alone is not determinative.
Ratio
POEM requires substantive control and decision-making, not just legal form.
Use via API
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curl https://api.thynktax.com/v1/tax-law/case-laws?q=Tata%20Sons%20-%20Treaty%20residence