The Income Tax Law includes a special stability provision regime available at Contractor’s election. If elected, this regime provides stability for the duration of the contract on the condition that the Qualified Extractive Industry Taxpayer agrees in writing to be subject to a 30 per cent tax rate.

Also, after the Bidders Conference, a new Paragraph 16.2 has been added to the Model EPSC:

”In the event that the Contractor should agree in writing that its taxable income shall be subject to an income tax rate of thirty (30) per cent for the remaining period of this Contract in accordance with Article 90 paras (2) and (3) of the Income Tax Law as in force on the Effective Date in order to obtain application of the Income Tax Law without regard to subsequent changes, and subsequently said provisions of the Income Tax Law are amended or replaced, and the Contractor as a result suffers income taxation over and above the agreed rate of thirty (30) per cent, then the Government shall indemnify and hold the Contractor (or its approved assignees) harmless from such taxation in excess of thirty (30) per cent.”