The certain principles relating to taxes contain in the Contract on Joint Development and the Equity Section of Production on Azeri's Fields and Chirag and Deep-water Part of the Field of Gyuneshli in the Azerbaijani Sector of the Caspian Sea signed on September 20, 1994 between the State Oil Company of Azerbaijan Republic and the Contract Parties and which came into complete legal force about December 12, 1994 ("Contract").
The Cabinet of Ministers of the Azerbaijan Republic published the Order No. 50 of March 7, 1995 about creation of the Commission under the leadership of the Deputy Minister of Finance of the Azerbaijan Republic consisting of representatives of the Ministry of Finance, Ministry of taxes, the State Customs Committee and State Oil Company of Azerbaijan Republic ("Commission") for establishment of the administrative rules necessary for implementation approved with the Contract parties tax the Contract provision.
The this Protocol entered force since January 1, 2002 and replaces the Protocols on the Taxation of Foreign Employees and Physical persons signed on May 31, 1996 and on April 25, 1996.
The commission and the Contract parties agreed to sign Protocols for establishment of these rules, including the this Protocol of January 1, 2002 about the Taxation of Employees and Physical persons ("Protocol"). In connection therewith the this Protocol determines their mutual understanding of the Contract and procedures which will be used in case of determination of the status of the taxation of Employees and Physical persons.
The this Protocol treats the taxation of the Contract parties, their Affiliirovanny companies, Operating company or Foreign Subcontractors ("Employer") or the employees who are or citizens of the Azerbaijan Republic ("The local employees"), or citizens of any other country, but not the Azerbaijan Republic ("The foreign employees"). In the this Protocol requirements for the reporting and tax withholding for persons which do not have employment relationships on permanent basis as employees with the Employer which are or citizens of other country, but not the Azerbaijan Republic, including persons without citizenship ("Foreign Physical persons") or are also stated are citizens of the Azerbaijan Republic ("Local Physical persons").
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