India - Draft Guidance of Place of Effective Management
- V.T. Patel; R. (Rajiv) Shah; K.P. Visharia
- International Transfer Pricing Journal, 2016 (Volume 23), No 3
- 18 May 2016
India has expressed a reservation in the Commentary on the OECD Model as regards the place of effective management, stating that the determination of the place of effective management should be guided by the place where the main and substantial activity of the entity is carried on. This reservation seems to have been taken into consideration when one considers the Indian Draft Guidelines for determining the place of effective management of a company under the Income Tax Act.