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taxpayer, with its first fiscal year for the short period ending
June 30, 1980.
EGPC's tax payments of its own tax liability are posted to
EGPC's tax file (No. 440/6) by the ETD. EGPC's tax returns are
audited by the Petroleum Section of the Department of Tax on
Joint Stock Companies within the ETD.
On EGPC's Egyptian income tax returns for years prior to its
taxable year ended June 30, 1993, EGPC credited royalty payments
and income taxes paid on behalf of its foreign partners against
its own income tax liabilities.
For the 1975 to 1980 tax years, ETD did not challenge the
credit taken by EGPC against its tax liability for taxes paid on
behalf of foreign partners, including Amoco Egypt. See infra pp.
42-46 for subsequent action by the ETD.
Egyptian Petroleum Concession Agreements - General Principles
Under Egyptian law and the Egyptian constitution, the ARE
owns all that country's natural resources. Rules and procedures
for granting concessions relating to the exploitation of the
ARE's natural resources are established by law. The Ministry of
Petroleum and Mineral Resources (formerly known as the Ministry
of Industry, Petroleum and Mineral Wealth) (both hereinafter
referred to as the Petroleum Ministry) whose top executive is the
Minister of Petroleum is part of the executive branch of the
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