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In an Internal Committee report dated January 19, 1992,
concerning the 1980-1981 tax year, there is no discussion of
foreign partner taxes. The final assessment for the 1980-1981
year, Forms 3 and 4, dated February 3, 1992, did not allow a
credit for royalties or taxes paid on behalf of foreign partners.
In another Form 19 concerning the 1980-1981 year, dated April 14,
1992, the ETD served a notice of tax assessment based on the
disallowance of a credit to EGPC. This was not a "revised" Form
19.
EGPC objected to the disallowance of credits for the 1980-
1981 year.
In January 1992, Ismail prepared a memorandum for the head
of the Tax Department for Joint Stock Companies describing EGPC's
treatment of royalties and foreign partner taxes, concluding that
EGPC's treatment was improper. Ismail discussed the issue with
his superiors in the department. The issue was then referred to
the ETD's Research Department in February 1992. Ismail
subsequently met with personnel from the Research Department,
described the adjustments he had made, and provided them with
copies of EGPC's tax returns and the MCA.
In Ismail's discussions with the Research Department, only
the Arabic text of the MCA was considered. The word "minha" in
Article IV(f)(6) was considered and, following Ismail's belief
that "minha" referred to the method of calculation, Ismail and
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