However, If branch profits cannot be determined, the Thai tax authorities have the right to issue a tax assessment equal to 5% of gross receipts. In our case, 5% of gross receipts would include the pass-through revenues Chevron pays to SDI Thailand, but would not include the expenses when such amounts were paid to Halliburton. As a result, SDI would pay corporate income tax partially based on pass-through revenues that ultimately get paid to Halliburton.