In the context of the possible introduction of an additional profit tax, the FPPG has called for an analysis of the constitutionality of introducing an additional profit tax (GST) on oil agreement holders.
Based on the premise that the GST will apply identically to all types of investments in the oil and gas sector (e.g. onshore, offshore, unconventional), the constitutionality analysis will be strictly limited to substantive law aspects related to the establishment of a new corporate income tax, additional to the one established by Title II of the Tax Code.
In drafting the analysis, Pachiu Associates used solutions of international arbitration practice and solutions of constitutional courts in other EU Member States (Italy and Estonia) that have been presented with cases almost identical to the one outlined by the establishment of an additional corporate income tax.
