EPC Contracts - BMR & Associates

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COMPOSITE SUPPLY AND INSTALLATION Mechanics Contractor • Composite contract for supply of goods and installation / commissioning Income tax Outside India Supply of equipment • Installation - PE exposure • Attribution of profits to PE Click India Installation and commissioning Buyer / Project owner • Risk to offshore supplies • No PE – FTS / no tax <strong>EPC</strong> CONTRACTS - FISCAL SCENARIO All rights reserved | 6
SERVICES Outside India India Offshore Service provider Offshore services Buyer / Project owner Onshore Service provider Onshore services Buyer / Project owner Outside India India Mechanics • Contract for services • Services may be offshore or onshore Income tax • Fee for Technical Services • “Make-available” and “Technical drawings” • Withholding taxes • PE exposure – service / fixed place PE • Work vs service Click • Attribution of profits to PE <strong>EPC</strong> CONTRACTS - FISCAL SCENARIO All rights reserved | 7
Page 1 and 2: T a x a n d R e g u l a t o r y EPC
Page 3 and 4: TAXES ON CONTRACTS - A SNAPSHOT EPC
Page 5: SUPPLY OF GOODS Structure 1 Structu
Page 9 and 10: COMPOSITE CONTRACT - EPC • Where
Page 11 and 12: INCOME TAX IMPLICATIONS Classificat
Page 13 and 14: SINGLE CONTRACT - SINGLE CONSIDERAT
Page 15 and 16: EPC CONTRACTS FOR OIL FIELD SERVICE
Page 17 and 18: EPC CONTRACTS FOR POWER PROJECTS
Page 19 and 20: INFRASTRUCTURE STATUS TO PIPELINES
Page 21 and 22: C h a l l e n g e U s EPC CONTRACTS
Page 23 and 24: INSTALLATION PE - SOME EXAMPLES Ins
Page 25 and 26: TAXABILITY OF SOFTWARE Recent rulin
Page 27 and 28: TAXABILITY OF AOP Separate taxable
Page 29 and 30: TAXABILITY OF AOP (CONT) Tax rate I
Page 31: INFRASTRUCTURE STATUS TO PIPELINES

EPC Contracts - BMR & Associates

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