New Delhi, Sept. 2 -- Under Indian income-tax law, the residential status of a trust determines the scope of income that may be subject to tax in India-broadly, worldwide income for a resident trust and India-sourced income for a non-resident trust.

Indian tax law does not prescribe a separate residence test specifically for trusts. A trust therefore falls within the residuary rule, under which every other person is regarded as resident in India in a tax year unless, during that year, the control and management of its affairs is situated wholly outside India.

A trust would qualify as non-resident only where its control and management, as exercised by its trustees, is wholly outside India. If even part of that control and management is e...