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law, Article IV(f)(6) provides a credit of Amoco Egypt's taxes
against EGPC's taxes rather than a deduction from income. We are
not persuaded that the gender analysis is as compelling as
respondent seeks to have us conclude. We think the juxtaposition
of the word "minha" in Article IV(f)(6) does not require that it
be attributed to the word "takhssim" (taxes) but that there at
least is a question as to the determination of from what the
deduction of taxes should be taken. In this connection, we think
it relevant that respondent's expert testified, with respect to
the new 1993 agreement, that the omission of the word "minha" did
not change the meaning of the tax provision, and that even
without the word, EGPC would be entitled to a credit. In effect,
this line of reasoning makes the presence of the term "minha"
irrelevant, so that the English and Arabic versions are virtually
identical. Such analysis undermines and is in direct conflict
with the evidence that, in 1993, Amoco Egypt, EGPC, and the ARE
intended to remove any doubt that EGPC get a deduction. It is
clear that, given the awareness of the problem and the stakes
involved, careful attention was paid in 1993 to ensuring that
there was no question that EGPC was not granted a right to a
credit. Indeed, this phase of testimony of respondent's expert
tends to weaken the impact of his advocacy of the significance of
the word "minha" in the 1975 MCA involved herein.
In short, we are satisfied that the mandate of the Arabic
version of Article IV(f)(6) is not so clear as to preclude us
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