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tweedledum-tweedledee situation; "subtract" and "deduct" are
synonymous. Webster's New Dictionary of Synonyms at 793 (1968).
The more critical difference rests on the significance of
the inclusion of the term "minha", meaning "therefrom".
Petitioner argues that "minha" refers not to EGPC's taxes as
finally determined but to the process of calculating EGPC's taxes
articulated in the opening clause of Article IV(f)(6), which is a
feminine concept in Arabic. Petitioner goes on to assert that if
we should conclude that the language of Article IV(f)(6) does not
unambiguously support its position then we should resolve any
ambiguity by looking to the intent of the parties.
Respondent argues that, because the Arabic word for taxes is
feminine, and because "minha" means from it or her, the provision
unambiguously instructs EGPC to deduct Amoco Egypt's taxes from
EGPC's own taxes. Respondent goes on to assert that Article
IV(f)(6) is inconsistent with the generally applicable principles
of deduction from income under Egyptian tax law. This being the
case, there is no basis for looking beyond the language of
Article IV(f)(6) to the intent of the parties since Article II of
the promulgation law, Egyptian Law No. 15 of 1976, accorded the
force of law to the MCA and operates as an exception to other
Egyptian laws, with the result that it should be strictly
interpreted.
We find it unnecessary to dwell upon the allegedly
inescapable conclusion that, because the MCA has the force of
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