The applicants submitted that the disposal of their interests under Article 23.5 of the EA2 PSA falls under the ITA and is governed by S. 89G(c) which reads: “Where a contractor, in this Part referred to as the “Transferor contractor” disposes of an interest in a petroleum agreement to another contractor or a person that as a result of the disposal will become a contractor in relation to those operations, in this Part referred to as the “Transferee contractor”- The applicants submitted that there was a sale of interests as witnessed by the SPAs which transactions were completed on the 21st February 2012.
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