Professional Documents
Culture Documents
Overview
Features of EPC contracts
Classification of
revenue streams
Offshore supplies
Offshore supplies
Offshore services
Onshore supply
Onshore supplies
Onshore installation
Services - unskilled
Local services
Onshore installation
Services - skilled
Onshore technical
services
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Duration of services
Income Tax
Situs of services
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Optimization of
taxes
minimization
of taxes
ensure
availability
of all
concessions/
exemptions
Certainty in
tax impact
definite taxable
base
responsibility to
pay tax
factor
change in law
Ease of
implementation
minimizing
exposures
avoiding
litigation
Commercial
imperatives
not to be
compromised
Single Contract
- Exposes entire
Sub-Contracts
- All parties are taxable
Contract
structures
Consortium Contracts
Multiple Contracts
- Optimizes taxes
and facilitates
planning avenues
Activities
-*
Offshore
Onshore/ Offshore
Offshore
Onshore/ offshore
Onshore
Onshore/ Offshore
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(contd)
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Onshore supply,
onshore services
and construction and
erection -- taxability not
in dispute
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Form v. Substance
Terms of the contract, Conduct of the parties and
Circumstances of the case are critical for building substance
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Way ahead
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Offshore services
Onshore supply
Onshore services
- unskilled
Project Owner
Performance
guarantee
agreement
Between
Project Owner
and Contractor
Onshore services
skilled
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Way ahead
(contd...)
Thank you!
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2007 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved.
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