Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 65

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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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