- 28 - under U.K. law -- all characteristics of taxes, not of payments for specific economic benefits. The parties herein rely heavily on expert witnesses -- from the petroleum industry, from the U.K. Government, and from legal, tax, accounting, and economic professions –- as to the character of PRT as a tax or as payment for specific economic benefits. The basis of the opinions rendered by respondent’s economic experts seems to be that, in hindsight, oil companies “got a good deal” when they entered into North Sea license agreements, that the licenses turned out to be more valuable than anyone anticipated at the time the licenses were issued, and therefore that the oil companies “probably felt there was an implicit contract” to pay some type of additional charges, and that these additional charges (whatever they may be called, however they are administered, and regardless of their features) should be regarded as what respondent’s expert witnesses refer to as “economic rent” (i.e., as deferred payments in exchange for the licenses granted in earlier years to the oil companies) and not as taxes. Respondent’s experts overemphasize the fact that North Sea licenses issued by the United Kingdom to the oil and gas companies in the late 1960's and in the 1970's were issued largely without an auction system. As we have found, throughout the world most countries traditionally have not relied on auctionPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011