8.1 [Orascom] shall be entitled, at its expense, to resist any Claim for and on behalf of in the name of [Iraqna] which is or could relate to a Tax Liability for which [Orascom] might be liable under paragraph 2, subject to the remaining provisions of this paragraph 8.
8.2 If [Atheer] or [Iraqna] becomes aware of a Claim (or any determination or direction in respect of losses which could increase a Tax Liability), [Atheer] shall give written details of the relevant matters to [Orascom] as soon as reasonably practicable.
8.3 [Atheer] shall (and where relevant, shall procure that [Iraqna] shall):
(a) take such action as [Orascom] may reasonably request in writing to avoid, dispute, defend, resist, appeal or compromise any Claim (or any determination or direction in respect of losses) (a "Disputed Claim"), subject to [Orascom] agreeing (to [Atheer]'s reasonable satisfaction) to indemnify [Atheer] or [Iraqna] (as applicable) against any reasonable costs which they may suffer or incur as a result of taking such action;
(b) make available to [Orascom] such employees of [Iraqna] or [Atheer] as [Orascom] may reasonably require and all information as may be available and as may reasonably be requested by [Orascom] for avoiding, disputing, resisting, appealing, compromising or contesting any such claim; and
(c) not accept or pay or compromise any such Claim without [Orascom]'s prior written consent.
...
8.5 Paragraph 8.3 shall not apply in respect of any Claim:
(a) to the extent that it would involve [Atheer] or [Iraqna] contesting a Disputed Claim beyond the first appellate body (excluding the Tax Authority which has made the Disputed Claim) in the jurisdiction concerned unless tax counsel appointed by [Orascom] confirms that ... it would be reasonable for [Orascom] to pursue that course of action; or
(b) if [Orascom] does not request [Iraqna] to take any action within 30 Business Days following [Orascom]'s receipt of written details relation to the Claim from [Atheer] in accordance with paragraph 8.2 (in which case [Atheer] or [Iraqna] shall be free to pay or settle the Claim on such terms as it reasonably considers appropriate).
9. Payment of Disputed Claims
In respect of a Disputed Claim, [Orascom] shall pay any required sum under paragraph 2 immediately following settlement, compromise or abandonment of the Disputed Claim unless the action requested by [Orascom] pursuant to paragraph [8.3] cannot be taken prior to the Tax the subject matter of the Disputed Claim being paid (in which case, an amount equal to that amount of Tax (a "Disputed Tax Payment") shall be paid by [Orascom] promptly upon receipt by [Orascom] of a written notice from [Atheer] for that amount). For the avoidance of doubt, if [Orascom] is required to make a Disputed Tax Payment and the Disputed Claim is settled or compromised for a lesser sum that the amount of the Disputed Tax Payment, the difference between the Disputed Tax Payment and the amount at which the Disputed Claim is settled or compromised shall be repaid promptly to [Orascom].
10. Payment of