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payments from EGPC's tax liability rather than from income and
that EGPC should pay all tax differentials for all open years.
Further, it was stated that EGPC would comply with the tax
department's determination both prospectively and retroactively,
and that by December 1992 it was expected that EGPC would have
completed payment of the tax differential for the 1980-1981 tax
year, and that payment for later years would follow a final
assessment by the tax department.
Also in November 1992, EGPC and Amoco Egypt, with the
approval of the Minister of Petroleum, entered into an agreement
whereby EGPC agreed to document for Amoco Egypt its compliance
with the ETD's determination concerning foreign partner taxes for
both prospective and retroactive purposes.
EGPC's deficiencies for the tax years ending June 30, 1981,
June 30, 1982, and June 30, 1983, have been paid. Payments were
made by check and posted to EGPC's tax file (No. 440/6).
In its Egyptian tax return for the taxable year ended
June 30, 1993, EGPC deducted foreign partner taxes in computing
taxable income and did not claim a credit for such amount.
1993 and 1994 Production Sharing Agreements
In 1993, Amoco Egypt, EGPC and the Egyptian Government
finalized a new production sharing agreement for the East
Shukheir Marine area. Under this 1993 agreement, EGPC assumed
the obligation to pay Amoco Egypt's Egyptian income taxes on
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