伊朗IPC合同与伊拉克服务合同对比分析

摘要

伊朗和伊拉克两个国家油气资源丰富,伊拉克于2009年推出风险服务合同,因为油气田规模较大,该合同模式受国际石油公司追捧.由于伊朗原采用的回购合同过于苛刻,以及其复杂的政治环境,导致很多资源国退出,2017年伊朗也借鉴伊拉克公开招标模式,采用类似于伊拉克服务合同的合同模式.该合同模式主要特点是合同者主要利润为单桶报酬费,无法获得高额利润.虽然两个国家合同模式均为服务合同,合同框架相同,但财税条款细节上却有较大差异,伊朗服务合同比伊拉克服务合同更为苛刻.本文主要介绍伊朗服务合同的推出,比较两伊服务合同模式财税条款和收入分配差异,以能更好的了解这两种合同模式的特点和差异,为更好的获取两伊新老项目提供评价基础.%Iran and Iraq are rich in oil and gas resources in the Middle East,risk service contract was adopted in Iraq in 2009.This kind of contract was also popular all over the world because of huge oil and gas filed in Iraq.The buyback contract in Iran was too restrict to employ,and the investment environment is a little bit complicated,many international oil and gas companies retreat from Iran.Iran studied from the opening bid of Iraq,also adopted risk service contract in 2017,which is similar to the contract of Iraq.The unique trait of this kind of contract is that the main profit is remuneration fee per barrel,so the contractors can't get huge profit.Although both contracts are risk service contracts and are similar workflow of revenue split,the details of fiscal terms are different.The contract of Iran is stricter than that of Iraq.The implementation of the contract of Iran will be introduced in the paper,and comparing the difference of fiscal terms and revenue split.It provides some information for understanding of this kind of contract and for the old and new project evaluation in Iran and Iraq.