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LETTER OF THE FEDERAL TAX SERVICE OF THE RUSSIAN FEDERATION

of May 22, 2013 No. ED-4-3/9183 @

About procedure for determination of coefficient of KV for the purposes of MET

The Federal Tax Service in connection with appeals of tax authorities concerning application of item 4 of article 342 of the Tax Code of the Russian Federation (further - the Code) for the purpose of the tax discharge on mining (further - MET) in case of oil extraction reports the following.

According to the subitem 9 of Item 2 of article 342 of the Code the taxation in case of oil extraction is made on the tax rate of 446 rub (for the period from 01.01.2012 till 31.12.2012 inclusive) and 470 rub (since 01:01. 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).

According to item 4 of the above-named article of the Code if degree of clarity of inventories of the specific subsoil plot more either is equal to 0,8 less or is equal 1, the coefficient of KV is calculated by formula:

KV = 3, - - 3, 5 x N/V,

where N - the amount of cumulative oil extraction on the specific subsoil plot (including losses in case of production) according to the state stock balance of minerals approved in year, prior year of tax period;

V - the initial recoverable oil reserves approved in accordance with the established procedure taking into account surplus and write-off of inventories of oil (except for write-offs of inventories of the extracted oil and losses in case of production) and determined as the amount of inventories of categories A, B, C1 and C2 by the specific subsoil plot according to data of the state stock balance of minerals on 01.01.2006.

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