LETTER OF THE FEDERAL TAX SERVICE OF THE RUSSIAN FEDERATION

of November 30, 2012 No. ED-4-3/20267 @

About severance tax

The Federal Tax Service in connection with the arising questions in case of determination of coefficient of the specific subsoil plot (KV) characterizing degree of clarity the stipulated in Clause 342 Tax Code of the Russian Federation concerning severance tax (further - MET) reports the following.

According to the subitem 9 of Item 2 of article 342 of the Tax Code of the Russian Federation (further - the Code) the taxation in case of oil extraction is made on the tax rate of 446 rub (for the period from January 1 to December 31, 2012 inclusive) and 470 rub (since January 1, 2013) for 1 ton of the extracted oil dehydrated, desalinated and stabilized. At the same time the specified tax rate is multiplied by the coefficient characterizing dynamics of world oil prices (Кц) on the coefficient characterizing degree of clarity of the specific subsoil plot (KV) and on the coefficient characterizing the size of inventories of the specific subsoil plot (Кз).

The item 4 of article 342 of the Code establishes the following procedure for determination of the size of KV in cases when degree of clarity of inventories of the specific subsoil plot (Св):

a) more either 0,8 is equal less or is equal 1 - the coefficient of KV is calculated by the formula established by this Item;

b) exceeds 1 - the coefficient of KV equal 0,3 is accepted;

c) in other cases (i.e. when Sv of the specific subsoil plot is less than 0,8) - the coefficient of KV is accepted equal 1.

Thus, according to the considered Code regulation, application in case of calculation of MET of this or that size of coefficient of KV is put into direct dependence on degree of clarity of the specific subsoil plot (Св).

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