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8/13/2019 IWE Report - Group 2
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Comparing the performance of the EPZs / SEZs in India
with the same in China and critically evaluating the
differences in their performance
IWE Report
2014
Group 2
Avneet Bhulania (Roll 09)
Divya Alapati (Roll 12)
Md Umair Ansari (Roll21)
Mohammad Haider (Roll 22)
Nitika Bansal (Roll 48)
Rahul Jain (Roll 50)
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Contents
INTRODUCTION ....................................................................................................................................... 3
ANALYSIS: FDI FLOW (India Vs China) ..................................................................................................... 4
China and India: Selected FDI indicators............................................................................................. 4
FDI Policies and Reforms: India Vs China ................................................................................................ 4
1. Policies ............................................................................................................................................ 4
2. Sunrise sector Investment .............................................................................................................. 5
3. Growth Rate and market potential ................................................................................................. 5
4. Investment Environment ................................................................................................................ 6
5. Macro-Economic Factors ................................................................................................................ 6
6. Undervalued Currency .................................................................................................................... 7
7. Special Economic Zones .................................................................................................................. 7
Incentive for Developer .......................................................................................................... 7
Incentive for the Manufacturers and Companies ................................................................... 7
Incentive for the country ........................................................................................................ 7
Who loses ................................................................................................................................ 7
INDIAN SEZ - Salient Features and Facilities ........................................................................................... 7
Facilities and Incentives for Developers ................................................................................................. 8
Impediments to the growth of Indian SEZs........................................................................................... 8
Small Size ............................................................................................................................................ 8
Location: .............................................................................................................................................. 9
Lop sided Growth ................................................................................................................................ 9
Lack of natural Gateway ..................................................................................................................... 9
Conclusions: .......................................................................................................................................... 11
1. Increase minimum SEZ area .......................................................................................................... 11
2. Promoting SEZ in mid size cities and coastal areas ....................................................................... 11
3. Development of manufacturing base and Singapore as natural gateway .................................... 12
4. Liberal Labor laws and Contract agreements within SEZs: ........................................................... 12
5. Stable economy and currency: ..................................................................................................... 12
6. Development initiatives from government: ................................................................................. 12
7. Development with social inclusion: .............................................................................................. 13
8. Reducing duties for imported goods in DTA: ................................................................................ 13
Policy Recommendations: ..................................................................................................................... 13
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INTRODUCTION
Foreign direct investment (FDI) as tool to boost growth of economy has been recognized by several
developing countries like Brazil, China, India, Taiwan etc. According to IMF, FDI is an international
investment to obtain a lasting interest by a resident entity in one economy in an enterprise resident
in another economy.
It results in a long-term relationship between the direct investor and the enterprise and a significant
degree of influence by the investor in the management of the enterprise including management
control. FDI is usually preferred over FII as FIIs are assumed to be attracted by short term gains and
tend to leave during times of trouble. In contrast to it, FDI investor cannot be pull out quickly, due to
lasting interest in the investment made and hence, more stable. Developing countries though are
trying to attract FDI but bulk of the FDI is still absorbed by the developed countries ($1.5 trillion in
US in 2004). China and India are two Asian giants which have lately been on the forefront of FDI
investments and both countries have evolved policies and implemented reforms to attract
investments.
India was the first country in Asia to create Export Processing Zones (EPZ) in kandla in 1965. SevenEPZs were established till 1990. However, India followed a strategy of self-reliance and import
substitution till 1980s. Foreign investment or private commercial flows were not preferred until the
launch of reforms in 1990- 91.
As per the survey conducted by ATKEARNY India and China are the two most promising destinations
for the FDI flow in the world. China has attracted around $52.7bn of FDI in year 2002 while the India
has attracted only $5.5bn during the same period. The FDI in china is around 3.2% of GDP while in
India it is only 1.1% of GDP in 2002. Though China started late (1978), it now receives FDI much
larger than India. This is despite the fact India has implemented institutional and financial reforms
better than China in the recent past. It is very clear from the above discussion that India is far behind
China. So there are important lessons that India can learn from China.
Capital markets governed by SEBI in India are better developed than China. India has succeeded in
services sector which is less capital intensive compared to manufacturing. Recent AT Kearney report
stated that India could become No.1 manufacturing destination. So it becomes even more
imperative to analyze China's success in manufacturing industry.
China's rise has been linked to the Special Economic Zones (SEZs) like Shenzhen, Guangdong, Podong
province which were developed by active support from Chinese government. But rather going gung-
ho about SEZs straightaway, we need to see the history of SEZ development in China and identify
differences between Chinese and Indian environment before committing to a development agenda.
SEZ/EPZ, as defined by the World Bank and the United Nations Industrial Development Organization
(UNIDO), is an industrial area that constitutes an enclave with regard to customs tariffs and the
commercial code in force in the host country and are intended to provide an internationally
competitive duty free environment and quality infrastructure for the promotion of exports at a
lower cost.
India has moved approved a SEZs at rapid pace trying to follow Chinese trajectory. We intend to look
in the historical development of SEZs in China and India and differences among them. Also if
required, analyze the need for a different trajectory to the one presently followed. The recent
debate on the proliferation of SEZs in India and ensuing opposition from the parties affected has also
mandated the assessment of benefits and costs of SEZs with a historical perspective.
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ANALYSIS: FDI FLOW (India Vs China)
As per definition, Foreign Direct Investment implies the fund that directly flows into the domestic
economy from the outside world. But It is interesting to note that what qualifies for Foreign Direct
Investment might differ between two countries. As per the IMF definition of FDI includes as many as
twelve different elements Viz.-Equity capital reinvested earning of foreign companies, Intercompany
debt transaction, Short-term and long-term loans, Financial leasing trade credits grants bonds, On-cash acquisition of equity, Investment made by foreign venture capital investors, Earning data of
indirectly held FDI enterprises, Control premium and Non-competition fee.
As pointed out by Dr. ARABI. U[2005] in his case study on china and India, Indian data on FDI did not
include any other element other than equity capital reported on the basis of issue or transfer of
equity or preference shares to foreign direct investor. China on the other hand, includes all the
parameters as per the definition of FDI. If we exclude all these parameters and also incorporate the
impact of the round tripping of Funds thru Honk Kong the estimated figure for China comes out to
be around $40bn. So effectively China has still attracted around 7-8 times of what India has
attracted. The same can be inferred from the following data:
China and India: Selected FDI indicators
The FDI in china is around 3.2% of GDP while in India it is only 1.1% of GDP in 2002. So it is very clear
from the above discussion that India is far behind China and hence there are important lessons to belearnt from China.
FDI Policies and Reforms: India Vs ChinaBelow is a comparison of Indian and Chinese experience with FDI as highlighted by Dr. S R Keshava
[2008] :
1. Policies:
Indian government has regulated the FDI flows through very unstable policies. Though the policies
are very liberal in nature but are equally rigid in spirit. For example In china the enterprises thatqualify as export oriented gets 50% tax exemption however in India there is no such provision at the
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same time there is no tax exemption on the import of the materials and equipments in India which is
the industry norm in China.
One way to create a better image of India as a business location will be to implement the policies
framed in their true spirit and also try to refrain from incremental policy changes (as is being done in
the case of the power and telecom sectors) so as to introduce stability in the system.
2. Sunrise sector Investment:
Today China is in the 2nd phase of its reforms and so it provides more conducive environment for
the FDIs particularly in those areas where China is lacking, the Chinese authority is not bothered
about the type of technology the Foreign Investor is bringing. The system is regimented and it has
ruled about a debate in political circles, which are very common in a democratic set up in India. This
type of system has been found to be very suitable for the foreign investors.
3. Growth Rate and market potential:
Both the countries have been enjoying the impressive growth rate since last two decades and have ahuge middle class population, so both are among the most favored FDI destination and are
competing for the FDIs. But if we look closely at the pattern of growth in china it proves out to be
significantly different from that of India.
China also performed basic land reforms programs though in arevolutionary way. For this reason
(accomplishing land reforms in a new democratic revolutionary path), China overtook India and
surged far ahead than India. This could be accomplished by China in a rapid manner because it
uprooted the feudalism and control of imperialism from the Chinese soil in a revolutionary way. So
China was placed in 1979 on a solid foundation when it started its journey along capitalist road
openly. This has not happened in India. India has taken a complete different path to that of China
taking the half hearted measures of land reforms in a bureaucratic way with an explicitunderstanding with feudalism and imperialism.As a result, the development ofcapitalism in India is
going on but very slowly; it is advancing, but in a limping and painful manner. Hence, the desire of
the ruling classes of India to accelerate its economic growth to catch China must be fallen flat as
China is running with full steam along the path of capitalist development completing its democratic
revolutions. Many learned people and pundits have forgotten this bitter fact.Moreover, another
bitter fact must be mentioned here. The engine behind the miracle growth of China is not its
export-led economy. In fact, theexports have served only a partial booster to the Chinas economy.
A strong internal market developed within China is in fact the real motive force behind the
development of China.The condition for this investment inmanufacturing is nothing but
development of the internal market or in other words, the development of capitalism in large scale
(which is in fact going on slowly and in a limping manner). China had accomplished democraticrevolution and basic land reforms long ago which was its basis of capitalist development
On the other hand due to this half hearted growth India is loosing on the revenue front as well. Now
most of the existing industries are vying for the SEZ status so as to derive special economic benefits.
For example POSCO which has applied for setting up a steel plant in Orissa in 2005 has later (after
declaration of new SEZ policies in FEB2006) applied for SEZstatus which is approved by GOI.
Ironically several IT companies which have not been offered any sops during initial phase are now
(after surviving more than 10 years of stiff competition) are also looking for a shift into SEZ.
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4. Investment Environment:
Non Resident Chinese are much more in number as compare to Non Resident Indians. Chinese are
more entrepreneurial in nature and they enjoy family connections (gaunaxi) in China. When they
choose to invest in China the govt. rolled out red carpet for them. However in India people lack
family connections and financial resources to invest in. Repatriation by NRC forms almost 66% oftotal FDI flowing in China, but the figure in India is only 3%. FDI is almost 10% of gross capital
formation in China while it is only 3.2% for India in 2002. The composite international country risk
guide rating is good for India, but China's rating is excellent. KPMG conducted a research on Global
Corporate Capital flows [2008] covering 300 corporate investment managers and private equity
funds which reveals the following:
Global corporate investment flows are switching from the U.S., Japan, Singapore and someEuropean countries to China, India, Russia and Brazil.
The U.S. economy should retain its position as a world leader, but is expected to share thisposition with China.
India is likely to lead in manufacturing investment, and the U.K. should be able to competeon equal terms with the U.S. in financial services.
European economies hold up well, but governments must find a way to counter theattraction of new markets in the BRIC countries if they are to keep their share of investment.
5. Macro-Economic Factors
Chinas manufacturing sector productivity is 1.6 times that of India and, in some sectors, as much as
five times [Mc Kinsey, 2001]. Flexible labour laws, a better labour climate and entry and exit
procedures for business, business-oriented and more FDIfriendly policies also make China an
attractive destination. Investors underscore the predictability and stability of the tax system as an
important factor in determining investment decision. Higher Import duties on raw materials in India
result in higher prices of inputs, as most domestic players resort to import parity pricing. China has a
flat 17 per cent VAT rate, while Indias indirect taxes rangefrom 25 per cent to 30 per cent of the
retail price for most manufactured product.
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6. Undervalued Currency
It is now widely acknowledged that Chinese exports have also been boosted by its undervalued
currency. This is a luxury that Indian exporters do not enjoy. The argument for setting up SEZs to
emulate China's export led growth is therefore questionable.
7. Special Economic ZonesThe primary motive of SEZs was to provide the incentives to the manufactures operating in the
region. In the geographical region recognized as Special Economic Zones the economic laws are
more liberal than other parts of the country. Idea behind the SEZs:
Incentive for Developer:The SEZ primarily consists of two parts SEZ units for setting up the factories or offices and
the residential area. The developer derives generous returns as many private and
commercial residential facilities do not mind paying a handsome amount for the first class
infrastructural facilities as it increases their productivity.
Incentive for the Manufacturers and Companies:Corporate and companies always get benefited by the tax heavens provided by the Law.Here as pointed out earlier the economic laws are more liberal.
Incentive for the country:From the basic principal of economics we know that for a country to sustain the economic
development it has to shift its excess labor from the agriculture to Industries. In India if a
labor moves from the agriculture (where marginal productivity is zero) to Industry (Where
marginal product is 4 times the agriculture) he/she will contribute more towards the GDP of
the country.
Who loses:Govt. in the form of tax holidays provided to the companies. But at the same time govt. alsobecomes free from the development of the region as the region become self sustaining and
eventually after 15 years when tax holidays will be over, government can earn good amount
of money. The govt. provides various facilities to the companies set up in SEZ. They are listed
below:
INDIAN SEZ - Salient Features and Facilities A designated duty free enclave and to be treated as foreign territory for trade operations
and duties and tariffs.
No License required for import. Exemption from custom duty on import of capital goods, raw materials, consumable spares
etc.
Exemption from Central Excise duty on procurement of Capital goods, raw materials,consumables spares etc. from the domestic market.
Supplies from DTA to SEZ units treated as deemed exports. Reimbursement of Central Sales Tax paid on Domestic purchases. 100% income tax exemption for a block period of 5 years, 50% tax exemption for next five
years u/s 10AA of the Income Tax Act.
Carry forwarded of losses.
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100% income tax exemption for 5 consecutive years & 50% for 5 years under section 80LA ofthe income tax Act for off shore banking units
Reimbursement of duty paid on furnace oil, procured from domestic oil companies to SEZunits as per the rate of drawback notified by the Directorate General of Foreign Trade.
SEZ units may be for manufacturing, trading or service activity. SEZ unit to be positive net foreign net exchange earner within three years. Performance of the unit to be monitored by a committee headed by Development
Commissioner and consisting of Customs.
100% foreign direct investment in Manufacturing, sector allowed through automatic routebarring a few sectors.
Facility to retain 100% foreign exchange receipts in EEFC a/c Facility to realize and repatriate export proceeds within 12 months Re-export imported goods found defective, goods imported from foreign supplier on loan
basis etc. without G.R. Waiver under intimation to the Development Commissioner
"Write off "of unrealized export bills up to 5% Commodity hedging by SEZ units permitted Capitalization of import payables. No Cap on foreign investment for SSI reserved items Exemption from industrial licensing requirement for items reserved for SSI sectors Profits allowed to be repatriated freely without any dividend balancing requirement
Facilities and Incentives for Developers Developers of SEZ may import / procure goods without payment of duty for the
development, operation and maintenance of SEZ. Income tax exemption for a block period of 10 year in 15 years at the option of developer as
per Section 80IAB of the Income Tax Act
Full freedom in allocation of developed plots to approved SEZ units on a purely commercialbasis.
Full authority to provide service like water, electricity, security , restaurants, recreationcenters etc. on commercial
Foreign investment permitted to develop township within the SEZ with residential area ,market, play grounds, clubs, recreation centers etc.
Develop Standard Design Factory (SDF) building in existing SEZ. Income Tax Exemption to investor's in SEZ's under Section 10(23G) of Income Tax Act. Exemption from Service Tax Investment made by individuals etc. in SEZ company also eligible for exemption u/s 88 of
the Income Tax Act. -
Impediments to the growth of Indian SEZs:
Small Size:
The government would be wasting its incentive package if it accorded SEZ status to processing
agglomerations or single units which were not appropriately sized to generate economies ofscale/agglomeration. It is in this context that a ceiling on SEZ size at 5000 hectares seems
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undesirable. As per the study conducted the ideal city size for making the maximum use of the
economies of scale should be between 1mn to 4mn. However in India most of the SEZs are of
smaller size which could have maximum of 5 lakhs of population considering the high density level of
10000 person /sq KM. Situation is even worse for the smaller SEZs. In India 43 out of 63 SEZs are
smaller than 1 Sq Km. so these SEZs could not make full use of the economies of Scale which is the
whole idea behind development of Special Economic Zones. Chinese SEZs of Schenzen and Hainanoccupy an approximate area of 400 square km and 34000 square km respectively.
Location:
Many of these SEZs are being developed as appendages to big cities. Therefore, they will suffer the
direct or side effects of the congestion and unmanageable size of these cities. For example, delays
caused by traffic gridlocks will spill over in to the SEZs. Proposals of SEZ development are coming up
largely for areas near or in big cities. The reason is the absence of good infrastructure (rail /road/
power etc) in other places. SEZ expansion is not a substitute for governments role in extensive
infrastructure provision and expansion, rather its role is in fostering centres of excellence in
manufacturing and service provision which are more than internationally competitive.
Diversification, expansion and improvement of road and rail networks and expansion of powergeneration capacity and distribution and transmission networks throughout the country would
stimulate a dispersed development of SEZs and thereby dispersed urbanization. Such a dispersed
development of SEZs would not only take the population pressure off agricultural land but also
facilitate the maximization of economies of agglomeration.
Lop sided Growth:
India needs to find new centres of urban growth. Compare the Indian case with China which had 100
cities with million plus population in 1990.. There were 67 cities (67%) in these 100 with a population
of 1-2 million each, another 25 (25%) with a population of 2-4 million each and only 8 cities (8%) in
the 4 million plus category. India had a population in 2001 which was comparable to that of China in
1990 but had only 36 million plus cities. However, the size distribution among million plus cities was
much more lopsided -23 cities (64% of the total number of million plus cities) in the population
range of 1-2 million, 6 (17%) cities in the 2-4 million range and as many as 7 cities (19%) in the 4
million plus range. Thus, not only did India have a much lower number of cities(36 cities) of million
plus size in 2001 as compared to China (100 Cities) in 1990, indicating a lower ability to exploit
potential economies of agglomeration, a much greater proportion of these large cities seem to have
crossed the optimal size. 4 million plus cities in China constituted just 8% of the total number of
million plus cities, whereas the corresponding figure for India was 19%. China did not have a single
city with a population of above 10 million in 1990 whereas India had 3 such cities in 2001.
Lack of natural Gateway:
In china the SEZ have been initially created so as to provide the cheap labor for manufacturing
industries of Hong Kong and Taiwan. These countries served as natural gateway (source) for capital
and movement of goods. For example for the SEZ in Guangdong acts as manufacturing base for Hong
Kong. Unlike China India has no such natural gateway though Dubai and Singapore are fast taking on
that role but still India is way behind China. Secondly India is more of a back office rather than a back
factory i.e. India gets its FDI largely into services where the investment required is much lesser than
setting up the manufacturing base.
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Labour Laws:
Labour Law is one of the major reasons for attracting FDI in China. Unlike India labour laws in China
are much more liberalize. The salient features are:
12 hours work in place of 8 hours; in most of factories/units overtime of 4 hours aremandatory. 7 days of work in place of 6 days. In the peak season there are instances of 24-hours of work. Many workers become senseless due to overwork; and even die.
Employments are available according to orders. After the expiry of the orders, the workersare retrenched.
Workers are collected from pool of (100 million) labour coming from countryside. 60% of theworkers engaged in the SEZs are female aged between 15-25 years who are cheaper than
the male workers. Most of the female workers have not right to be pregnant. If so, they are
retrenched.
Each worker has to sign a contract form at the time of joining. But most of the workers donot know what are written in these contract forms giving more leeway of exploitation and
deprivation. A certain amount of money must be deposited in hands of the
managers/owners of the units at the time of joining lest they should run away.
The wages are very much low (one-seventh of the US level). Workers have to sleep in dormitories with little space to move. Most of these dormitories
are abysmally unhygienic. The meal allotted to them cannot feed them properly. Health of
most of the workers breaks due to overwork. Female workers, when they reach 25 years, are
retrenched generally citing the cause of ill health. The male workers are exhausted before
30-35 years of age. They have rightsof getting pension after retirementbut only in
papers in most of the cases.
There are no environmental standard in these SEZs. Workers are forced to work in unhealthy& unhygienic conditions. Industrial accidents are regular features. In most of the cases the
owners of the units do not take any responsibility of the treatment of these workers. Even
the government sheds its responsibility in many occasions.
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Conclusions:
1. Increase minimum SEZ area:
India has a policy of establishing sector specific Special Economic Zones. In such SEZs the economies
of scale are really difficult to achieve and so the proper benefits of the SEZs do not percolate to thesociety on the other hand the Ministry of Finance ended up losing the export subsidy provided under
the DEPB scheme. So what we propose is to increase the minimum size of SEZs and should
concentrate on establishing the large size quality SEZs instead of concentrating on large number. If
India continues to approve the small size SEZs then it ended up establishing the subsidized
enterprises and low cost real estate development projects in the disguise of economic development
for the society and country.
2. Promoting SEZ in mid size cities and coastal areas:
As pointed out earlier in the paper that India had developed most of the Special Economic Zones at
the out skirts of the Major Cities. This actually prevents the benefits derived from the subsidizeddevelopment to the backward areas of the country. Also we know that with the increasing
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population will increase the burden on existing land holdings and this will further reduce the already
existing low marginal product in Agriculture. It is therefore paramount to wean away the excess
labor to manufacturing sector. This entails that we should focus on the development of the SEZs in
the small and mid size cities and to facilitate the cheap transportation preferably in coastal areas.
With the recent spurt in prices of agricultural goods and the stagnation in production of agricultural
commodities have made it critical to protect our prime agricultural lands. Barren lands or the oneswith little output should be developed by Government to generate further interest in private
players.
3. Development of manufacturing base and Singapore as natural gateway:
For sustained economic growth and continuous FDI flow in Special Economic Zones, it is very much
desirable to promote India as a back office for the developed countries in manufacturing sector too.
In this regard Singapore and other ASEAN countries seem to be a first logical option. If India could
prove its abilities in manufacturing sector as it proved in Services then it would be a great
competitive advantage. For this we recommend to work towards development of mechanism for
generation of information about potential markets, development of exporting infrastructure and
eliminating bureaucracy.
4. Liberal Labor laws and Contract agreements within SEZs:
One of the biggest deterrents in the flow of foreign investments in India is its strict Labor Laws and
restricted hire fire policies. In India it is really difficult to set up a base but it even more difficult to
wind up. Contract Labor is not allowed in most of the sectors. However we believe that it is the need
of the hour and India should realize that contracted Labor will benefit the labors as well, as it will
allow them to switch work between their farms during the agricultural season and manufacturing
during the lean season. The hindrance in the relaxation of Labor Laws is that it may provoke the
exploitation of labors by the industrialists. But organized sector governed by proper employee
benefits is miniscule compared to the unorganized sector. Having a contract would rather securetheir rights to consideration to their work as justified under the law. So we still believe that relaxing
the hire and fire policy and providing the contractual labor, at least within the SEZs will be in the
interest of both the parties.
5. Stable economy and currency:
India has a policy of free float currency and so Indian Rupee fluctuates with the changes in demand
and supply of the rupee. Sometimes due to global impact the rupee appreciates heavily and makes
the exports very uncompetitive in the world market. Such huge fluctuations in the currency arereally unwarranted. What we recommend to implement is a policy of a free float currency in a
specific band or tie-up it with a basket of currencies as done by China. Now as India sitting on the
pile of foreign reserves and so she can afford to do so.
6. Development initiatives from government:
As seen in the Chinese development model, Government should proactively develop SEZs and
arrange for requisite infrastructure. For developing SEZs of a scale as hugeas the Chinese one,
Government is the most suitable contender as it can mobilized resources and various departments
rather than a private player whose prime motive would be Return on Investment made.
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7. Development with social inclusion:
Government should ensure that the sites boost the overall growth of country. Developing SEZs in
states which are lagging compared to other states can help to alleviate the inequities which will
boost overall consumption. The size of domestic market as seen in case of China is equally important
for attracting investment.
8. Reducing duties for imported goods in DTA:
An industrial base in Indian SEZ might require raw materials or components which are not available
in India. In such cases, if waiver or reduction of duties is given, it might help in attracting FDI. Else it
will be pulled by any other country ready to forgo short term revenue to develop competitiveness in
that sector.
Policy Recommendations:
Government should increase the minimum size of new Special Economic Zone from existing5000 hectares to 1 mn hectares. New SEZs should be developed in the medium sized cities rather than at the out skirts of
metros.
India should strive for better business ties with Singapore and US, and should avail majoreconomic benefits available to the companies from ASEAN region.
Government should permit for 12 hours of work per day under special circumstances andrelax the hire and fire policies within SEZs.
Companies should be allowed to employ contractual labour under the guidance of SEZauthority appointed by the Government (may be after paying a predetermined
compensation above the minimum pay regulations).
Indian currency should also be allowed to free float within a range i.e. it is not allowed toappreciate/depreciate beyond a certain range or tied up to a basket of currencies as done by
China.
Provide subsidies and reduce taxes for the manufacturing companies in SEZs rather thansoftware companies already enjoying competitive advantage.
Duties imposed on the sale of goods to the DTA from SEZ should be reduced or should getaway with in case of goods which are imported.
Government should include the development of SEZs in its 5-year plan. It may be a publicprivate partnership initiative like Build-Operate-Transfer (BOT) model.