The CIAT Executive Secretariat invites you to download and read chapter “3.15. Artificial Fragmentation of Contracts” from the Manual for the Control of International Tax Planning, written by Tatiana Falcão.

This chapter analyzes the two main contractual structures that historically tend to be fragmented: large ‘EPC’ contracts (Engineering, Procurement and Construction) and ‘turnkey’ contracts. It also describes the main challenges that countries face when taxing these services due to tax planning, treaty limitations and legal disputes. Additionally, it offers experiences and good practices used by countries that have a legal framework to avoid the fragmentation of contracts.

This is chapter number 30 published within the framework of the “Manual for the Control of International Tax Planning“, available in English and Spanish. The complete Manual has six chapters made up of 42 sections. New sections will be published soon.