In this arbitration, the Claimant has made the following prayer for relief (as is stated in its latest submission, i.e. its Supplemental Quantum Submission): “[…] Crystallex respectfully requests that the Tribunal: DECLARE that: (i) Venezuela has breached Article VII(l) of the Treaty by expropriating the Claimant’s investments in Venezuela; and (ii) Venezuela has breached Article II(2) of the Treaty by failing to accord the Claimant’s investments in Venezuela fair and equitable treatment, and full protection and security; ORDER that: (iii) Venezuela pay the Claimant the sum of USD3,160,000,000 for its breaches of the Treaty or such other amount as the Tribunal determines is a consequence of (i) and (ii); (iv) Venezuela pay pre-award interest in the sum of USD1,034,174,685, calculated from the Valuation Date to 12 September 2014 or such other amount as the Tribunal considers will ensure full reparation and thereafter at a commercially reasonable rate of 8% per annum until the date of the Tribunal’s Award, compounded semi-annually, or at such other rate and compounding period as the Tribunal determines will ensure full reparation; (v) Venezuela pay post-award interest on (iii) and (iv) above at a commercially reasonable rate of 8% per annum from the date of the Tribunal’s Award, compounded semi-annually, or at such other rate and compounding period as the Tribunal determines will ensure full reparations [sic]; DECLARE FURTHER that: (vi) The award of damages and interest in (iii), (iv) and (v) is made net of applicable Venezuelan taxes; and (vii) Venezuela may not deduct taxes in respect of the payment of the award of damages and interest in (iii), (iv) or (v); ORDER FURTHER that: (viii) Venezuela indemnify the Claimant in respect of any double taxation liability that would arise in Canada or elsewhere that would not have arisen but for Venezuela’s adverse measures;