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SEZ & EPCG Advisory
Capital Structuring

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).

0%
Duty on Capital Goods
6-Year
Export Obligation Window
100%
Final Exit Compliance Ratio

The Obligation Trap

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.

EPCG Default Risk

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 DTA Friction

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.

De-bonding Paralysis

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).

License Non-Transferability

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.

Life-Cycle Institutional Defense

Greenfield Structuring

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.

Real-time EO Tracking

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.

De-bonding Execution

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.

Case Study

Healthcare Capex Relief

Client Profile

  • • Advanced Diagnostic Equipment Manufacturer
  • • Importing German precision scanning machinery to manufacture in India
  • • Capex Value: ₹50 Crores
  • • Facing a prohibitive 15% Basic Customs Duty on imports

The Scaling Block

  • • Paying ₹7.5 Cr in duty upfront destroyed the project's initial IRR (Internal Rate of Return).
  • • The company had a 30% export guarantee to the Middle East, but brokers advised against EPCG due to "fears of compliance audits."

Our Execution

  • • Evaluated their 6-year export projections and confirmed a massive safety margin for Export Obligations.
  • • Procured the EPCG License, slashing the ₹7.5 Cr duty to absolute zero.
  • • Mapped out a secure, document-heavy fulfillment plan allowing partial redemption of their bond year-over-year to minimize risk exposure.
₹7.5 Cr
Capital Expenditure Saved
0%
Duty Paid Upfront
₹45 Cr
Structured Export Obligation
100%
Final Redemption Rate

"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

Questions & Answers

Capital Structuring Rules

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.

  • Financial Clawback: You must immediately pay back the entire exempted customs duty, plus penal interest running at 15% per annum calculated from the original date of import.
  • Operational Blacklist: The DGFT may place your company on the Denied Entity List (DEL), completely blocking your ability to import any goods or claim future export incentives until the default is regularized.

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:

  • 1. The DTA buyer must file a regular Bill of Entry.
  • 2. Standard Basic Customs Duty (BCD) and IGST must be paid on the transaction value.
  • 3. The SEZ unit must have achieved Net Foreign Exchange (NFE) positivity over a 5-year block to maintain its underlying tax holiday status.

Deploy Capital Without Duty Friction

Before importing heavy machinery or setting up a new manufacturing zone, consult with us to eliminate the 15% upfront duty barrier legally.