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Microlesson · 5-min read

Residential Status of Company & POEM

# Residential Status of a Company [Section 6(3)]

## Indian Company

An Indian Company is ALWAYS a Resident in India — irrespective of where its control or management is exercised.

(An Indian Company is one formed and registered under the Companies Act in India.)

## Foreign Company

A foreign company's status depends on Place of Effective Management (POEM):

POEM LocationStatus
In IndiaResident
Outside IndiaNon-Resident

```

Foreign Company

┌──────────┴───────────┐

POEM in India POEM outside India

│ │

Resident Non-Resident

```

## What is Place of Effective Management (POEM)?

POEM means the place where key management and commercial decisions that are necessary for the conduct of the business of an entity as a whole are, in substance, made.

  • It is a substance-based test, not merely the place of incorporation or where Board meetings are held formally.
  • It focuses on where decisions are actually made, not just rubber-stamped.
  • POEM is to be determined annually.

## Key Points

  • Companies do not have an ROR/RNOR distinction — only Resident or Non-Resident.
  • POEM is irrelevant for an Indian Company — it remains Resident regardless.
  • POEM is the sole test for a foreign company; the 'control and management' wholly/partly test (used for HUF/Firm/AOP) does NOT apply to companies.

Worked example

### Example 1

Indian Company

ABC Ltd. is incorporated in India. Its Board operates from Dubai for all decisions.

→ Being an Indian Company, always Resident. POEM is irrelevant.

### Example 2

Foreign Company — POEM Test

XYZ Inc., incorporated in USA. Its CEO and senior management make all strategic decisions from a Mumbai office; the US office only executes them.

→ POEM is in India → Resident foreign company.

→ Worldwide income becomes taxable in India.

If the same decisions were made in New York, POEM is outside India → Non-Resident.

⚠️ Common exam mistakes

  • Treating an Indian Company as Non-Resident because management is abroad — Indian Companies are always Resident, period.
  • Applying 'control & management wholly/partly in India' test to companies — that test is for HUF, Firm, AOP, etc., not companies.
  • Classifying a Resident foreign company as ROR/RNOR — companies don't have that classification.
  • Confusing POEM with the place where Board meetings are formally held — POEM looks at the substance of where commercial/management decisions are actually taken.
  • Forgetting that POEM is determined year by year.
Reference: Section 6(3) — Income Tax Act, 1961
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