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Egyptian General Petroleum Corporation
The Egyptian General Petroleum Corporation is a legal entity
first created by Egyptian Law No. 167 of 1958. Pursuant to
Egyptian Law No. 20 of 1976, the powers, functions, and
obligations of EGPC were assumed by a new legal entity also known
as the Egyptian General Petroleum Corporation (both entities are
hereinafter referred to as EGPC). EGPC is subject to Egyptian
income tax. Further facts in respect of EGPC are set forth and
discussed below, infra pp. 82-83.
Gulf of Suez Petroleum Company
The Gulf of Suez Petroleum Company (GUPCO) was formed by
Amoco Egypt and EGPC pursuant to the 1964 Gulf of Suez Concession
Agreement. GUPCO was later designated as the operating company
for all operations pursuant to the merged concession agreement
discussed below. GUPCO has a board of directors consisting of
eight members, four of whom are designated by Amoco Egypt and the
other four by EGPC. The chairman of the board is designated by
EGPC.
Government Structure for Egyptian Tax Administration
The Egyptian Tax Department (ETD) is a department of the
Finance Ministry responsible for the assessment and collection of
taxes.3
3 Egyptian Law No. 14 of 1939 provides that an annual tax is
established, "on the profits from professions and commercial,
industrial, and artisan operations, including mining and other
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