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LETTER OF THE MINISTRY OF FINANCE OF THE REPUBLIC OF KAZAKHSTAN

of April 6, 2011 No. HK25/5577

Tax departments on areas, the cities of Astana and Almaty

The Ministry of Finance of the Republic of Kazakhstan in connection with the arising questions concerning severance tax, reports the following.

According to the subitem 2) Item 1 of article 334 of the Code of the Republic of Kazakhstan of 10.12.2008. "About taxes and other obligatory payments in the budget" (further - the Tax code) by transfer by the subsoil user as raw materials supplied by the customer for conversion on the oil refinery located in the territory of the Republic of Kazakhstan, or realization to the third party for the subsequent transfer as raw materials supplied by the customer for conversion on the oil refinery located in the territory of the Republic of Kazakhstan, and (or) use by the subsoil user for own production needs - as the work of the actual amount transferred by the subsoil user as raw materials supplied by the customer for conversion to the oil refinery located in the territory of the Republic of Kazakhstan, or implemented to the third party for the subsequent transfer as raw materials supplied by the customer on the oil refinery located in the territory of the Republic of Kazakhstan and (or) use by the subsoil user for own production needs of crude oil, gas condensate, and production cost of production of the unit of production determined according to International Financial Reporting Standards and requirements of the legislation of the Republic of Kazakhstan about financial accounting and the financial reporting increased by 20 percent.

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