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based on income or profits including all dividend,
withholding with respect to shareholders and other
taxes imposed by the GOVERNMENT of A.R.E. on the
distribution of income or profits by AMOCO
[Egypt].
6. In calculating its A.R.E. income taxes, EGPC shall
be entitled to deduct all royalties paid by EGPC
to the GOVERNMENT and AMOCO [Egypt]'s Egyptian
Income Taxes paid by EGPC on AMOCO [Egypt]'s
behalf.
Article IV(f)(2) defines Amoco Egypt's annual income for
Egyptian income tax purposes, which includes the market value of
oil received by Amoco Egypt, plus an amount equal to Amoco's
Egyptian income tax liability computed in the manner shown in
Annex E to the MCA. Annex E, regarding accounting procedures and
tax implementing provisions, provides:
It is understood that any A.R.E. income taxes paid
by EGPC on AMOCO [Egypt]'s behalf constitute additional
income to AMOCO [Egypt], and this additional income is
also subject to A.R.E. income tax, that is "grossed-
up".
Article IV(f)(6) is identical to Article III(f)(6) of the
1973 Esso agreement and to the version initialed by EGPC and
Amoco Egypt on November 16, 1975. It is also identical in
substance to the August 4, 1975, draft of the MCA.
Article XXIII(a) of the MCA provides:
Any dispute arising between the GOVERNMENT and the
parties with respect to the interpretation, application
or execution of this Agreement, shall be referred to
the jurisdiction of the appropriate A.R.E. Courts.
Article XXVI of the MCA provides:
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