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Инвестор отремонтирует памятник солдатам у бывшего кинотеатра "Брест" в Москве

Then again, the Tribunal considers the brief repetition of selected of its conclusions within the context of distinct concerns required or no less than appropriate to be able to avoid misunderstandings and prevent the necessity to consult with earlier distinct sections of its Award.

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There could be no dispute the actions taken by the Russian Federation deprived Yukos of its assets and conveyed them by auction to alone and no dispute which the Russian Federation compensated no payment for all those assets. [ ]

b. Profit taxes: The Tribunal considers that the lawful landscape in outcome throughout the period by which Yukos claimed the tax Positive aspects within the Very low Tax Locations was outlined by ambiguous legislation which Yukos Evidently utilized to its edge. Even so, the subsequent re-software of amorphous rules of "fantastic faith" and "proportionality" with fluid levels of financial investment being designed within the Minimal Tax Regions can be a j weak defence by Respondent presented the scale on the tax assessed while in the re-evaluation audits commencing in December 2003 and Yukos’ openness in taking advantage of that tax regime if the Original audits ended up performed and in addition had been from bona fide and discriminatory in check out on the cure of other comparable providers making use of identical strategies to avoid taxes.

(b) Ordering the Russian Federation to pay interest on the quantity awarded at a traditional commercial level, for instance LIBOR additionally 4%, compounded semi-yearly from your day of valuation until eventually full payment is built;

Задержан глава департамента градостроительства Самары

Specified the terms of Write-up 5(1) of the Expense Security and https://rosinvest.com Advertising Settlement in between the Soviet Union and the uk (IPPA) the Tribunal will be grateful to hear within the Functions what exam ought to be applied so as to find out whether or not a evaluate not in by itself amounting to "nationalisation or expropriation' really should be considered a measure "having influence similar to" nationalisation or expropriation,

Although the tax assessments ended up subject matter to overview under Article five of the UK-Soviet BIT, which they aren't, Claimant has not rebutted the presumption of bona fide taxation. As demonstrated below, Claimant has unsuccessful to ascertain which the tax assessments were either mala fide or discriminatory or confiscatory. Annex AA plus the supplemental expert report of Mr. Oleg Y, Konnov rebut Each and every in the arguments lifted by Claimant and Professor Maggs with respect to taxes, and show the steps from the Russian tax authorities were being absolutely in step with both Russian law and Worldwide tax practice. In particular, Respondent and Mr.

The only plausible rationalization for Claimant’s termination of Elliott Intercontinental’s financial fascination within the Yukos shares during the midst of Yukos’ ongoing liquidation was the Elliott Group’s want to reap the benefits of the rights thought to be available underneath the United kingdom-Soviet BIT - rights that Obviously wouldn't happen to be available to Elliott International, a Cayman Islands company. Inside the absence of the reputable expectation of knowing a return with the economic exercise of a heading problem, even Claimant’s 2007 acquisition of an financial interest during the Yukos shares did not constitute an "financial investment" throughout the which means of Short article one (a) of the united kingdom-Soviet Little bit.

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(b) Nor has the Russian Federation rebutted the evidence that the tax assessments had been discriminatory, because the treatment of Yukos from the Russian tax authorities was significantly distinct from its cure of other in the same way situated Russian oil companies.