- 34 - the Egyptian Government, as compensation for no longer taking tax credits for Amoco Egypt's taxes. In January 1981, Amoco submitted another ruling request to the IRS seeking a determination that taxes paid by EGPC on Amoco Egypt's behalf under the existing agreements were creditable. Amoco believed that the basic provision whereby Amoco Egypt's taxes were paid by EGPC would pass muster under the temporary regulations and, if so, that it would not be necessary to continue the difficult negotiations on the PPIA approach. In stating the reasons why the Egyptian tax system met the requirements for a creditable tax under section 903, Amoco stated: "No portion of Amoco's tax is refunded to it, nor is any portion of such tax used directly or indirectly to provide a subsidy to Amoco." The computation of EGPC's taxes was not addressed, and Amoco did not indicate that EGPC had claimed a tax credit for taxes paid on behalf of Amoco Egypt. In February 1981, EGPC formed a new negotiating team that included Mansour. Mansour was more amenable than the previous lead negotiator, Kaptan, to handling the loss of EGPC's right to the credit under Article IV(f)(6) through a reduction in the royalty rate. In March 1981, Amoco Egypt sent a letter to EGPC to resolve an impasse over a "keep-whole" clause. The clause was requested by EGPC as a means of recovering from Amoco Egypt the difference,Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
Last modified: May 25, 2011