对于具体的EPC项目来说,应当注意分析其国内法对设计费性质的界定一般而言,EPC项目指的是业主将工程的设计、采购、施工等主要工作委托给总包方来组织实施,并由总包方对工程的质量、安全、工期和费用承担总体责任的项目安排方式。由于EPC合同安排中业主与总包方以至分包方,很可能是不同税务管辖地的税务居民,而项目实施过程中又往往不 For a specific EPC project, attention should be paid to the analysis of the definition of the nature of design fees by its domestic laws. Generally speaking, an EPC project means that the owner entrusts the main work of project design, procurement and construction to the general contracting parties for organization and implementation, And by the total package side of the project’s quality, safety, duration and cost of the overall responsibility for the project arrangement. Due to the fact that the owners and the general contracting parties in the EPC contractual arrangement and the subcontracting parties are likely to be tax residents in different tax jurisdictions, the project implementation process often does not