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taxes paid by EGPC on behalf of Mobil, from its, EGPC's, taxable
income.
Egyptian Law No. 107 of 1973 and Law No. 108 of 1973,
authorizing the Minister of Petroleum to enter into the Mobil and
Esso agreements, respectively, were promulgated by presidential
decree. Both laws, and the respective agreements, in both
English and Arabic, were published in the Egyptian Official
Gazette on October 4, 1973. The Arabic versions of Article
III(g) of the Mobil agreement and Article III(f)(6) of the Esso
agreement both include the term "minha" after the word for
"deduct".
1974 Amoco Egypt Production Sharing Agreements
In 1974, Amoco Egypt entered into three Egyptian production
sharing agreements: the South Gharib, South Ghara Marine, and
South Belayim Marine Concession Agreements. The 1974 Amoco
agreements were patterned after prior Egyptian production sharing
agreements. The tax provisions of the agreements were not the
subject of any negotiation.
Article III(f)(6) of the 1973 Esso agreement served as a
model for the provisions in the 1974 Amoco agreements governing
EGPC's tax treatment of its tax payments on behalf of Amoco
Egypt.
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