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Place of effective management: SARS’ viewsPlace of effective management (POEM) remains a key determinant of the South African tax residence of juristic persons. This is the case despite it no longer being the tie-breaker in the OECD Model Tax Convention to resolve dual residence. SARS recently revised Interpretation Note 6, which deals with POEM. This article considers the continued role of POEM, the core principle in IN6 as well as the changes to the note. |
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