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POEM & Residency
Safeguarding Offshore Structures

Place of Effective Management (POEM) rules can instantly reclassify a foreign subsidiary as an Indian tax resident, taxing its global income at 40%. We audit board substance, mandate operational protocols, and build defensible shields against residency disputes.

Ideal for: Indian Promoters with UAE/Singapore holding entities, Outbound Tech Startups, and Multinational JVs.

100%
POEM Audit Defense Rate
₹200+Cr
Foreign Income Protected
4 Weeks
Rapid Substance Review

The Paper Director Illusion

Indian assessing officers routinely deploy "substance over form" to disregard offshore holding unities. Relying solely on a certificate of incorporation or local nominee directors is no longer a defense against global taxation.

Promoters in India

If the Indian parent company or its directors are calling the shots via email or WhatsApp directing the foreign subsidiary's actions, the true decision-making "Place" is India.

Risk: Decisive management control traces back to the Indian IP address.

Virtual Boards

Post-COVID, offshore board meetings shifted online. If controlling directors join the meeting from Mumbai, the legal locus of that "offshore" board meeting is India.

Risk: Physical locus of the directors determines the locus of the board.

Financial Dependency

If the foreign treasury, banking authorities, or capital expenditure approvals require sign-off from the Indian parent, the offshore entity lacks commercial independence.

Risk: Lack of localized operational funding and control.

Corporate Substance Protocols

Diagnostic Reviews

We dissect board minutes, executive travel logs, email authorizations, and banking architectures to identify latent POEM triggers before the assessing officer does.

Board Structuring

Designing localized governance. We draft the protocols for physical meetings, ensure the local directors are adequately qualified, and enforce pre-read documentation rules.

ABOI Safe Harbors

Testing the "Active Business Outside India" parameters mathematically to secure the legal presumption against Indian residency.

Litigation Defense

When notices are served, we build the factual and evidentiary matrix proving that decisive control was fundamentally exercised in the foreign jurisdiction.

Case Study

Defending Global Residency: UAE Holding Co.

Client Profile

  • • Real Estate & Investment Holding in Dubai
  • • Controlled entirely by Indian resident promoters
  • • Generating ₹120 Cr in annual global investment income
  • • Subjected to Indian POEM scrutiny assessment

Tax Department Allegations

  • • Directors resided in India due to temporary travel restrictions
  • • Significant capital investments were allegedly initiated via email sent from Mumbai
  • • Assessing officer proposed taxing the entire ₹120 Cr UAE income at 40% in India

Our Execution

  • • Conducted forensic email extraction proving local UAE managers prepared the investment memos
  • • Produced notarized physical board minutes held in Dubai prior to travel restrictions
  • • Demonstrated distinct local banking control and localized commercial substance
  • • Prevailed at CIT(A), dismissing the entire POEM assertion
₹120 Cr
Global Income Protected
Zero
Indian Tax Levied
4
Off-shore Board Meetings Structured
100%
Penalties Rescinded

"The sheer threat of our UAE entity being taxed as an Indian resident would have effectively bankrupted our holding structure. Sami's team stepped in, organized our chaotic historical documentation into a pristine, impenetrable defense file, and completely shut down the assessing officer's POEM allegations."

— Managing Director, Dubai Investment Group

Questions & Answers

POEM Clarifications

Understanding the transition from paper directors to substantive offshore governance.

POEM is triggered when 'key management and commercial decisions' in substance are made in India.

The Income Tax Department looks beyond paper boards to identify the real decision-makers. Common triggers include:

  • Indian Promoters: Indian residents holding decisive control over foreign subsidiaries.
  • Passive Off-shore Boards: Foreign directors who only 'rubber stamp' decisions pre-approved by the Indian parent.
  • Virtual Meetings: Holding the majority of board meetings via video conferencing where the controlling directors are sitting in India.

Turnover threshold: POEM provisions apply only to foreign companies with an annual turnover exceeding ₹50 Crores.

The consequences are catastrophic for international tech and holding structures.

Global Taxation

The foreign entity's entire global income becomes taxable in India at the 40% foreign corporate tax rate (plus surcharge).

Compliance Nightmare

The entity must now file Indian tax returns, withhold Indian TDS on all its foreign payments, and adhere to Indian transfer pricing rules.

ABOI provides a 'safe harbor' presumption that POEM is outside India.

To qualify for ABOI, the foreign company MUST meet ALL four conditions:

  • Passive income (royalties, dividends, capital gains, interest) is less than 50% of total income.
  • Less than 50% of its total assets are located in India.
  • Less than 50% of its total employees are situated in or reside in India.
  • Payroll expenses on Indian employees are less than 50% of total payroll.

Even if you meet ABOI, the majority of board meetings still must be held physically outside India.

Audit Your Decision Substance

A single email from an Indian promoter could trigger global taxation. Let us stress-test your offshore board protocols against aggressive Indian POEM standards before a notice is issued.