Thread regarding Shell Oil layoffs

India Service Center comes with financial risk. Learn from Chevron how not to mess up..

Realize that there are significant number of well enumerated drone workers at Shell, but doing business in and traveling to India have potential regulatory burdens…the Chevron model.

Summary of the Situation

Chevron has invested approximately $1 billion in its Engineering and Innovation Excellence Center (ENGINE) located in Bengaluru, India. While this expansion is intended to improve efficiency and global project collaboration, there may be long-term tax and compliance costs associated with how the operation is structured under Indian law.

The following sections outline general, factual information based on standard international taxation frameworks such as Permanent Establishment (PE) and Transfer Pricing — not internal Chevron data.

Permanent Establishment (PE) and Tax Liability
• If a foreign company establishes a fixed place of business in India (for example, an engineering or project office), Indian authorities may classify it as a Permanent Establishment (PE).
• This triggers tax obligations on profits attributed to work performed in India, even if the project serves clients elsewhere.

Profit Attribution
• Under Indian law, part of a company’s global income can be taxed locally if significant value creation or management occurs in India.
• For instance, if Australian or U.S. projects are executed by teams in India, India can claim a portion of those profits for taxation.

Taxation of Foreign Subsidiaries
• Corporate Tax: Subsidiaries or branches in India are taxed on income earned locally, typically around 22% (plus surcharge and cess).
• Transfer Pricing: Intercompany transactions (e.g., management fees, subcontracting, asset transfers) must follow India’s arm’s-length pricing rules.
• Withholding Tax: Payments from India to foreign parent entities (royalties, fees, or dividends) may face withholding taxes depending on applicable treaties.

Cross-Border and Expat Implications
• Projects Managed from India: Even if work supports projects in Australia or the U.S., India can still tax the related income if the work is performed domestically.
• Foreign Expats in India: Employees from other countries working in India may be taxed under Indian income tax laws based on their residency status.

Estimated Financial Impact (Industry Benchmarks)
Benchmarking studies (e.g., from KPMG and EY) indicate potential cost impacts in several areas:
• Transfer Pricing Adjustments: 5–15% increase in taxable income due to stricter cost scrutiny (e.g., management fees, FX losses, share-based pay).
• Profit Attribution: 15–25% of global project profits could be attributed to India for high-value engineering or design work.
• Compliance Costs: Ongoing regulatory, IT, and operational costs may total $2M–$5M annually depending on scale.

Five-Year Projection (2025–2030):
• Transfer Pricing Adjustments: estimated at $10 million to $20 million per year, totaling $50 million to $100 million over five years.
• Profit Attribution Tax Impact: estimated at $15 million to $30 million per year, totaling $75 million to $150 million over five years.
• Compliance and Administrative Costs: estimated at $2 million to $5 million per year, totaling $10 million to $25 million over five years.
• Total Global Business Unit Cost: approximately $27 million to $55 million per year, or $135 million to $275 million over a five-year period across all Chevron business units utilizing the Indian center.

Strategic Considerations
While India offers substantial cost and talent advantages, aggressive profit attribution and tax compliance requirements could partially offset those savings. This highlights a broader issue many multinationals face when expanding shared services or engineering hubs abroad.

Sources:
• Indian Income Tax Act and Transfer Pricing Rules
• OECD Guidelines on Permanent Establishments
• Public benchmarking data from KPMG and EY

Would be interested to hear others’ perspectives on how these kinds of global engineering consolidations impact overall efficiency and cost management across Chevron’s business units.


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| 1751 views | | 9 replies (last November 7) | Reply
Post ID: @OP+1k8enaphr

9 replies (most recent on top)

Oooo! A tax post! How exci- zzzzzzz ...

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Post ID: @21n+1k8enaphr

@h7 if they do not have a 1 day headache again and take such (paid) sick leaves a couple of times a month. Or 6 months parental leave for the youngsters in BLR. Working for Shell India is the best WLB there is. Indians know what hard work is (service company), so they rather stay with Shell.

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Post ID: @j3+1k8enaphr

@f1 wait a day is being generous. My experience has been wait at least two days for them to get back to you only for them to ask how to do the job you just asked them to do...but maybe a manager is different.

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Post ID: @h7+1k8enaphr

All of these potentially negative ramifications were thoroughly vetted by the LC. While it was agreed serious financial pitfalls are distinct possibilities, they went around the table and asked if anyone’s personal bonus structure or departure payout would be threatened. Everyone answered “nah, I’m good”.

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Post ID: @f2+1k8enaphr

@dg

yep. it went from one person in an “expensive location” doing a task to 4 people in india and one 20% time “expensive location” person to do the same things. this somehow is more cost efficient. right. i feel like the real issue here is how much we measure costs. clearly the incentives are based around per capita day rate and should not be.

it gets even worse when project managers are in india to “reduce cost”. you can’t even talk to them and they can’t even talk to you, how are they managing the project? the answer is they either don’t or we wait a day for every single blocker.

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Post ID: @f1+1k8enaphr

I think offshoring went too far in many companies and I guess at some point the reverse will start happening in 5 years time, or by that time many companies will just go bust. The idea has been cool on paper, centralize processes to integrate and as cherry on the cake it being cheaper but in the end you create a system where it takes 10 people to change a light bulb and often the light remains broken.

Not even saying this as a bitter onshore person but as someone who works in one of the hubs. And for many people in the hub even visiting the businesses you support is near impossible because travel budget is for the bourgeoisie management that needs the travel budget for cheerleading team building sessions

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Post ID: @dg+1k8enaphr

@at

I haven’t experienced literally any positive changes under Wael

as a JG4 in the US, he even cut my ability to get stock unless I get JG3 and froze all promotions and team changes for two years. work continues to go to people in india who can’t do the job then call me for help but try to get out of writing me a charge code.

the stock is up. however it’s also true that the billions he spent on buying back our stock would have made more money by throwing darts at the S&P 500. its also true that revenue is down 28% year over year.

when he leaves in 1-2 years (average shell ceo tenure is 4 years (coincidentally close to how long it takes to vest stock grants), it will rapidly become obvious that we have no assets and nothing in the pipeline. then the real legacy of wael begins.

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Post ID: @cr+1k8enaphr

@as how will wael’s administration or era be recognized as?
Do a simple SWAT analysis…if you drilled down to 1 ply toilet paper 🧻 you surely can share your perspective both positive and negative attributes

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Post ID: @at+1k8enaphr

you keep reposting this as comments and threads but i am never really able to tell what questions you have, if any

what is your point? do you think we don’t have people running the numbers on india who understand taxes?

do you think it matters if it costs more than the leadership would prefer or planned for as long as its still the cheapest option? it doesn’t. they will do whatever saves even one dollar. i’ve watched reduce cafeteria days and move to single ply toilet paper. if it saves a buck under wael, absolutely nothing is too low

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Post ID: @as+1k8enaphr

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