{"url":"https://lrlabs.ai/t/domestic_principal_role_expl2a","engine":"deterministic","llm_in_path":false,"id":"domestic_principal_role_expl2a","question":"Does Indian domestic law have a principal-role agency test?","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)","confidence":"settled","as_at":"14 Aug 2026","quote":"habitually plays the principal role leading to conclusion of contracts","quote_string_verified":true,"quote_source":"provision:IN.ITA.S9-1-I"}