- 46 - 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 andPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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