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"На сегодняшний день активно строится второй этап обхода (Твери — ИФ), включая искусственные сооружения.

d. Although Russian legislation governed the relationship involving Claimant and CSFB, and perhaps if CSFB had acted as Claimant’s "Fee agent", Claimant would in fact happen to be performing because the agent for Elliott Worldwide, the principal and useful operator on the shares for as long as the Participation Agreements were in impact, (¶¶5-nine RPHB-n)

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The sequence of functions, as well as sheer range and accumulation of hostile steps, all stage to the conclusion that the Russian Federation abused its tax enforcement powers to expropriate strategic petroleum assets managed by a political opponent of your Russian Condition:

Document Request; Claimants to begin rolling creation of paperwork in response to requests not objected to.

b. Income taxes: The Tribunal considers the lawful landscape in result during the time period by which Yukos claimed the tax Positive aspects from the Reduced Tax Areas was defined by ambiguous legislation which Yukos Obviously used to its advantage. Even so, the following re-application of amorphous ideas of "excellent religion" and "proportionality" with fluid amounts of expenditure to generally be manufactured from the Very low Tax Areas really are a j weak defence by Respondent offered the scale from the tax assessed within the re-evaluation audits starting in December 2003 and Yukos’ openness in taking advantage of that tax regime once the Original audits had been conducted as well as ended up from bona fide and discriminatory in check out from the remedy of other comparable corporations utilizing comparable methods to stay clear of taxes.

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seven million, or, in the alternative, equivalent to the value that expense would've experienced in the date of the award absent Respondent’s unlawful expropriation of your assets of Yukos;

• The Russian Federation has didn't rebut the evidence the revenue tax strategies used by Yukos have been legal in the course of the a long time in query and that the Russian governing administration was nicely aware of Yukos’ utilization of These strategies from prior audits of Yukos and. on the trading companies managed by Yukos.

Объект культурного наследия регионального значения на Волочаевской улице построен в начале ХХ века по ...

(four) The provisions of this text relative into the granting of Most Favoured Nations therapy shall not be construed in order to oblige one https://rosinvest.com particular Contracting Social gathering to extend to the buyers of another Contracting Celebration, Choices or privileges resulting from:

In interpreting that clause and importing Posting 8 from the Denmark-Russia Little bit into the present dispute, the Tribunal appreciates that conflicting arguments are doable Within this context: a. On just one hand, it may be argued that it's important to browse that provision during the context of your treaty of which it sorts an element. Write-up eight in the Denmark-Russia Little bit permits a claimant of 1 contracting party to the treaty to claim for expropriation by another contracting celebration. On the other hand Post eleven states that the treaty would not utilize to taxation. So Article 8 on the Denmark-Russia Little bit in its context does not implement to statements located in taxation. The Tribunal is bound to import Short article 8 in https://rosinvest.com its context, i.e. subject to Short article 11. Were a Danish investor to make a declare underneath the Denmark-Russia BIT for an expropriation by way of taxation, the remedy afforded on the Danish investor beneath the Denmark-Russia Little bit would indicate the Trader was precluded from making a claim.

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