[ compiled answer ]
law as at 14 Aug 2026 · settled
Does Indian domestic law have a principal-role agency test?
The compiled answer
Yes — Finance Act 2018 BEPS-ified Explanation 2(a) to s.9(1)(i): an agent who habitually plays the principal role leading to conclusion of contracts creates a business connection domestically. The treaties mostly do NOT contain that limb (only India–Netherlands, via the MLI), so a treaty-entitled enterprise takes the narrower treaty test via s.90(2) — the domestic/treaty gap is the whole point.
Pinpoint
Explanation 2(a) to s.9(1)(i), Income-tax Act 1961 (FA 2018)
String-verified quote
“habitually plays the principal role leading to conclusion of contracts”
source: provision:IN.ITA.S9-1-I — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/domestic_principal_role_expl2a.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)