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FSUOGM                                        COMMENTARY                                            FSUOGM




       Russian finance ministry proposes





       sweeping changes to new profit-





       based tax regime






       There were hopes that the profits-based system would replace the
       current mineral extraction tax regime within a decade.




        RUSSIA           RUSSIA’S Finance Ministry (MinFin) has filed  Yamalo-Nenets and Komi, with depletion rates
                         a bill seeking to adjust a new excess profit tax  of between 10% and 80%, that started produc-
       WHAT:             (EPT) system applied last year at certain oilfields,  tion no later than January 1, 2011. Their oil and
       Russia's Finance Ministry   in order to reclaim some RUB213bn ($2.9bn) in  gas condensate output had to be no more than
       has proposed changes to   tax receipts that were lost because of the system’s  15mn tonnes (300,000 barrels per day) in 2016.
       a trial excess profit tax   introduction. But unsurprisingly, the ministry’s   The final category covers fields in the Tyu-
       (EPT) system introduced   plan is strongly opposed by oil producers that  men, Khanty-Mansiysk, Yamalo-Nenets and
       last year.        benefitted from the new regime.      Komi regions with depletion rates equal to or
                           Russia launched the pilot EPT scheme last  less than 5% of initial recoverable reserves below
       WHY:              year at various categories of upstream projects,  10mn tonnes (73.3mn barrels). To be eligible,
       The ministry is trying   as part of efforts to reform the oil industry’s  their total hydrocarbon reserves must not be
       to reclaim some $2.9bn   complex and problematic tax regime. The initial  more than 51mn tonnes (374mn barrels).
       in tax receipts lost   goal was to expand the new system to the entire   The tax rate under the EPT regime was set
       because of the system's   industry within 10 years, replacing the mineral  at 50%, with the tax base consisting of revenues
       introduction.     extraction tax (MET), which levies taxes based  from hydrocarbon sales, minus export duties,
                         on production volumes rather than profitability.  transportation costs, MET taxes, operating and
       WHAT NEXT:          However, the MinFin later dismissed the  capital expenditure and selling, general and
       A compromise will likely   EPT system’s introduction as a mistake, not only  administrative (SG&A).
       be reached between the   costing the federal budget greatly but also failing   For fields in the third category, the sum of
       need to replenish the   to incentivise investment as hoped. This is at a  opex, capital and SG&A is capped at RUB7,140
       budget and avoiding   time when Russia is grappling with a significant  per tonne ($13 per barrel) in the first two years,
       too great a hit to oil   decline in budget revenues, as a result of the eco-  rising to RUB9,500 per tonne after 2021. It will
       companies' earnings.  nomic fallout from the coronavirus (COVID-19)  also be indexed annually by CPI after 2021.
                         pandemic, low oil prices and OPEC+ production   There are no opex limits for other fields dur-
                         cuts.                                ing their first three to eight years of production.
                                                              Operators are allowed to carry forward project
                         The regime as it is                  losses in order to reduce taxable income with
                         Four categories of oilfield were given the option  a 16.3% annual indexation. Historical losses
                         of switching to the EPT system last year. The first  incurred since 2011 for category-1 and cate-
                         category is fields in the Yakutia, Irkutsk, Kras-  gory-2 fields, and since 2007 for category-4
                         noyarsk and Nenetsk regions, as well as others  fields, are taken into account when calculating
                         partially in the Yamalo-Nenets region and above  the tax base.
                         the 65th parallel north, and in the Russian waters
                         of the Caspian Sea. To qualify, fields in these  Proposed changes
                         areas should have depletion rates of no higher  The MinFin submitted its bill to other relevant
                         than 5%, or their oil reserves need to have been  ministries on July 29, sources told Kommer-
                         registered with the state no earlier than January  sant last week. The bill consists of four main
                         1, 2017.                             proposals.
                           The second category covers fields that already   The first and most significant one is that oil
                         qualify for export duty relief. Cuts in export duty  companies should not be allowed to lower the
                         have mostly been applied at fields that are in  tax base under the EPT system by more than
                         remote areas, or are geologically complex, driv-  50% by carrying forward historical losses. At
                         ing up development costs.            present, up to 100% of historical losses can be
                           The third category relates to older fields  carried forward.
                         in the regions of Tyumen, Khanty-Mansiysk,   Secondly, beginning in 2020, historical losses

       P4                                       www. NEWSBASE .com                         Week 32   12•August•2020
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