four. The issue if the steps of Respondent have to be regarded as expropriations underneath the UK-Soviet Little bit is transferred towards the merits phase of this arbitration. 6 billion in taxes, curiosity, and fines. The timing on the audits and pace with which the tax authorities instantly uncovered an alleged US$ 24.one billion tax fraud ar

Even assuming quod non that this Tribunal has jurisdiction more than Claimant’s declare, there was no expropriation for which Claimant could recover. Being an Preliminary make a difference, Claimant by itself expressly disclaims an expropriation in the Yukos shares. Claimant alternatively seeks, based on a misreading of Short article five(2) of t