30+ years of combined expertise in complex Indian taxation and compliance.
Discuss your unique tax situation with our senior partners. No obligation.
30+ years of combined expertise in complex Indian taxation and compliance.
Massive industrial expansion requires duty-free capital accumulation. We structure EPCG licenses to drop upfront machinery duties to 0%, while architecting SEZ and MOOWR frameworks to shelter long-term manufacturing operations from indirect tax friction.
Ideal for: Heavy Engineering Plants, Semiconductor Foundries, Healthcare Chains, and Tech Parks (₹50Cr+ Capex).
Duty-free capital equipment is never truly "free." Government programs like EPCG and SEZ impose stringent, multi-year export and compliance burdens. Mismanaging these obligations converts a tax incentive into a devastating liability.
Committing to an Export Obligation (6x duty saved) without mathematically mapping future production capacity. If global demand shifts and you fail to export, the government demands the original duty plus crippling 15% interest.
SEZ units attempting to pivot sales into the Domestic Tariff Area (DTA) face complex valuation challenges, unexpected IGST levies, and failure to maintain the mandatory Net Foreign Exchange (NFE) positive threshold.
Executing a strategic exit (de-bonding) from an SEZ or EOU scheme. The valuation of depreciated capital goods and the payment of residual duties is highly adversarial and often results in massive SCNs (Show Cause Notices).
Undergoing an M&A transaction or location shift while holding active EPCG licenses or SEZ approvals. Failure to formally amend permissions prior to the shift triggers immediate cancellation of benefits.
Modeling capex plans against SEZ, EOU, MOOWR, and EPCG. We conduct mathematical feasibility studies to select the framework offering the highest NPV (Net Present Value) based on your specific domestic-to-export ratio.
For EPCG holders, we install tracking protocols mapping shipping bills (e-BRCs) directly to license obligations. We actively manage 'Clubbing' of licenses to offset under-performing machinery with over-performing lines.
Architecting the exit. We negotiate straight-line depreciation values with customs authorities during EOU/SEZ de-bonding to minimize final residual duty payouts and secure seamless 'No Objection' clearances.
"Our expansions were capped by the 15% upfront duty on German medical scanners. Kuppusami's team engineered an EPCG license strategy that brought our capital expenditure tax down to zero, and they mapped out an export fulfillment plan that was actually realistic and perfectly defensible."
— CFO, National Healthcare Equipment Manufacturer
Understanding DGFT penalties, DTA sales, and export obligation mathematics.
The Export Promotion Capital Goods (EPCG) scheme allows you to import heavy machinery and capital equipment at 0% Customs Duty.
The Trade-Off (Export Obligation):
In return for the 0% duty privilege, you must export goods worth 6 times the duty saved over a period of 6 years.
Example: You import a ₹10 Cr machine that normally carries ₹1.5 Cr in customs duty. You pay ₹0. You are now legally obligated to generate ₹9 Cr (6 x 1.5) in export revenue using that machine within 6 years.
Defaulting on an EPCG obligation triggers severe financial and operational penalties.
Sami Tax specializes in "Clubbing" of licenses and structuring ad-hoc extensions to rescue defaulting units before DEL invocation.
Yes, but it legally equates to an import into India.
Special Economic Zones (SEZs) are considered foreign territory for trade purposes. When an SEZ unit sells goods to a domestic (DTA) buyer:
Before importing heavy machinery or setting up a new manufacturing zone, consult with us to eliminate the 15% upfront duty barrier legally.