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FSUOGM                                        COMMENTARY                                            FSUOGM


       Kremlin may have to intervene





       in latest oil tax row






       The use of the profit-based tax system caused a $2.7bn shortfall in the budget




        RUSSIA           PRESIDENT Vladimir Putin might have to  customs code in 2021-23.
                         intervene and mediate the tension between   Sberbank sees Rosneft and Gazprom Neft
       WHAT:             the Finance Ministry and Russia's oil majors  as the key beneficiaries of the EPT so far, hav-
       Russia trialled a new   over the new excess profit tax system (EPT),  ing made gains of $2bn and $1.2bn respectively.
       profit-based tax system   Kommersant daily reported citing unnamed  Gazprom Neft made most of its savings at the
       last year.        sources.                             Novoport project in the Russian Arctic.
                           The price of the question is over RUB200bn   "Just the introduction of the 1.5 coefficient
       WHY:              ($2.7bn) of tax benefits that the ministry seeks to  into the EPT formula (instead of 0.4-0.8) for
       The system's adoption led   reclaim from Rosneft, Gazprom Neft and others.  2021-23 would boost the tax bill for Rosneft's
       to the finance ministry   "The crux of the disagreement is that the first  EPT greenfields by more than $2bn and for
       losing $2.7bn in tax   experiment with the EPT, applied to a number of  Gazprom Neft's Novoport by $0.8bn," accord-
       receipts.         fields from various companies in 2019, resulted  ing to Sberbank CIB calculations, which rep-
                         in RUB213bn less tax revenue than MinFin had  resent a respective 5% and 4% of their market
       WHAT NEXT:        estimated," BCS Global Markets explained on  capitaliation.
       The system is likely to   August 3.                      Sberbank CIB expects the discussion over the
       be tweaked rather than   In the meantime, the MinFin’s insistence on  proposed tax amendments to be "quite heated"
       abandoned.        claiming back the "lost" revenue has caused a  in the coming weeks and sees resistance to draft
                         backlash from the oil companies, particularly  legislation from both oil companies and the
                         state-owned Gazprom Neft and Rosneft. Those  Energy Ministry. In its current form it implies
                         companies are reportedly the largest beneficiar-  material risks for the state-controlled Rosneft
                         ies of the unexpectedly profitable nature of the  and Gazprom Neft, the analysts warned.
                         EPT system for new extraction fields in remote   "Although MinFin’s intention to amend the
                         Russian regions, BCS GM said.        EPT tax regime was voiced previously, we think
                           BCS GM believes that the MinFin will  the markets did not fully realise that certain
                         get some revenue recovery, but less than the  measures might be implemented already from
                         RUB213bn it is claiming.             2021," VTB Capital (VTBC) commented on
                           "In return, the EPT will be tweaked sub-  August 3, seeing the potential changes to the
                         stantially, and will likely eventually replace the  regulatory regime as negative for the industry’s
                         existing, increasingly complex tax system, mak-  fundamentals.
                         ing a large number of complex, small or remote   Given that Gazprom Neft and Rosneft have
                         fields economically attractive for oil producers to  higher exposure to EPT, the companies are set
                         develop," BCS GM analysts argue.     to be hit more than peers if the changes in the
                           Sberbank CIB, however, on August 3 argued  tax regime are introduced, VTBC warned, while
                         that "the draft legislation would considerably  anticipating more newsflow on the subject,
                         reduce the attractiveness of the EPT regime for  which will be negative for oil stocks' sentiment.
                         oil companies, primarily because it would more   The analysts at VTBC calculate that Gazprom
                         than halve the cost compensation inflation rate."  Neft’s Ebitda might decline by $1.1bn (22%) and
                         This is a big factor for projects' IRR, the bank  $0.9bn (15%) in 2021-22 under an oil price of
                         believes.                            $45-47 per barrel. Rosneft’s EBITDA might
                           The proposed changes to the regime, which  decrease $440mn (2.4%) and $990mn (4.7%) in
                         would apply to all EPT-eligible fields, according  2021-22.
                         to Kommersant, include reducing the historical   The energy ministry and much of the oil
                         cost compensation inflation rate from 16.3% to  industry have long called for the adoption of a
                         7.0%, limiting the amount of compensation to  nationwide profit-based tax system, which they
                         50% of the taxable base from 2020 and reduc-  say would be more responsive to changes in mar-
                         ing the upper limit for the deductible cost base  ket conditions and encourage producers to focus
                         to RUB8,000 per tonne starting in 2025 (ver-  more on their efficiency. As it stands now, Rus-
                         sus RUB9,520 per tonne in 2021 in the current  sian producers mainly pay levies in the form of
                         legislation).                        mineral extraction tax (MET) and export duties.
                           In addition, the ministry has reportedly pro-  Tax breaks are rewarded on a case-by-case basis,
                         posed setting the tax holiday coefficient to 1.5x  typically to those companies with the strongest
                         for fields in Group 2 of the Eurasian Union's  lobbying power in government. ™



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