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(1) Neither Contracting Occasion shall in its territory issue investments or returns of investors of the opposite Contracting Get together to cure a lot less favourable than that which it accords to investments or returns of investors of any 3rd State.
"В рамках реализации девелоперского проекта инвестор проведет ремонт памятника "Поднимающий знамя", стоящего около здания бывшего кинотеатра "Брест" на Ярцевской ...
BFG was a Unique goal vehicle for Rosneft, the state oil firm that had owned many of Yukos' belongings ahead of their privatization within the nineteen nineties Which now owns them yet again.
• Lastly, the concentrating on of organization individuals and lawyers affiliated with Yukos and its shareholders, the procedural inequities from the Russian court docket proceedings, and the disparate procedure of Yukos’ opponents all contradict the Respondent’s ongoing professions of good religion.
3.nine The Parties are invited to remark in better detail on the connection that has been alleged to exist involving the prison prosecutions of Mr. Khodorkovsky and also the reassessments in the taxes claimed to get because of from Yukos.
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b. Earnings taxes: The Tribunal considers that the authorized landscape in result in the interval during which Yukos claimed the tax Positive aspects from the Low Tax Areas was defined by ambiguous legislation which Yukos Evidently accustomed to its benefit. On the other hand, the subsequent re-application of amorphous rules of "good religion" and "proportionality" with fluid amounts of investment decision being produced while in the Very low Tax Locations can be a j weak defence by Respondent supplied the dimensions with the tax assessed inside the re-assessment audits starting in December 2003 and Yukos’ openness in Benefiting from that tax routine if the initial audits were conducted and likewise ended up towards bona fide and discriminatory in watch from the procedure of other comparable corporations employing equivalent methods to avoid taxes.
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• "The District Court docket is of the view which the course of affairs as represented... can only result in the conclusion that the way where the additional tax assessment owed by Yukos Oil, and the size thereof,ws assessed initially because of the Russian Tax Authorities and subsequently with the tax court docket cannot stand the test of criticism.
3.three. Until normally agreed concerning the Events or dominated with the Tribunal, witnesses and specialists may very well be existing while in the Listening to area over the testimony of other witnesses https://rosinvest.com and specialists.
To depart without doubt that the expropriation of your property of a firm also constitutes expropriation of an expense in shares in this kind of firm, Short article five(2) from the IPPA expressly confirms which the standard of security in Write-up 5(1) applies: "In which a Contracting Bash expropriates the property of an organization or business and that is included or constituted under the regulation in pressure in almost any Component of its very own territory, and through which traders of the other Contracting Get together Have a very shareholding, the provisions of paragraph (1) of this text shall use."
Events to post final notifications to one another and also the Tribunal of which witnesses and specialists offered by by themselves or by one other Celebration that they need to examine in the Hearing. [phrases in italics additional]
Numerous consequences stick to from this condition of affairs, which serially and collectively https://rosinvest.com mandate the dismissal of Claimant’s declare.