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FSUOGM                                       COMMENTARY                                            FSUOGM




























                         will be indexed at 7% per year for the purpose of  the company’s EBITDA will weaken by $664mn
                         the tax carry-forward, rather than 16.3%.  or 12% in 2021 and $661mn or 10% in 2022, if it
                           Thirdly, the deductible costs per tonne will  is unable to carry these losses forward.
                         remain unchanged at RUB7,140 per tonne   The development economics of the compa-
                         up until the end of 2024, instead of rising to  ny's oil rim projects might also suffer, the bank
                         RUB9,520 per tonne in 2021. They will rise only  said, as well as the Kuyumbinskoye field in East-
                         to RUB8,600 per tonne in 2025.       ern Siberia, where it is partnered with Rosneft.
                           For the second group of fields – those that   Rosneft would similarly be hard hit if the
                         enjoy export duty relief – the ministry wants to  ministry’s proposals are adopted. Unable to fully
                         increase MET rates. It suggests applying a 1.5x  reflect its historic losses in the lower tax base, its
                         coefficient to their MET rates between 2021 and  EBITDA could be $697mn, or 4% less, in 2021
                         2023. But this will also affect companies’ ability  and $776mn, or 4% lower, in 2022, according to
                         to reduce their tax base beyond the threshold  VTBC.
                         level defined by deductible costs.     Affected Rosneft projects include Yurubche-
                           Under the current regime, companies were  no-Tokhomskoye, Tagulskoye and Trebs and
                         able to reduce the tax down to zero through car-  Titov, as well various brownfields and smaller
                         rying forward their historical losses as long as  greenfields such as Lodochnoye, Naulskoye and
                         this MET co-efficient was below 1. Essentially,  Labaganskoye.
                         this will further limit how much companies are   Lukoil’s only major project where the EPT
                         able to reduce their tax base by carrying forward  system is applied is the Pyakyakhinskoye field
                         historical losses.                   in Western Siberia, which accounted for 32,000
                           The MinFin estimates that these measures  bpd, or 2%, of its liquids output in 2019. That
                         would bring an extra RUB87.8bn ($1.2bn) in  project has $2.8bn in historical losses, and the
                         tax revenues in 2021 and RUB55.6bn ($0.75bn)  company’s inability to carry these forward could
                         in 2022. It expects to collect an additional  cut its EBITDA by $19mn in 2021, VTBC esti-
                         RUB200bn ($2.7bn) in total between 2021 and  mates. A lower cap on deductible costs may
                         2023.                                erode a further $8mn of its earnings.
                                                                EPT also governs a number of smaller Lukoil
                         Implications                         fields that produced 94,000 bpd, or 6%, of its
                         VTB Capital (VTBC) estimates that Russian  oil last year. The company could lose $51mn of
                         oil firms will take a 3.2% hit to their EBITDA in  EBITDA in 2021 because of lower deductible
                         2021 if the ministry’s proposals are introduced,  costs at these fields, as well as $1mn because of
                         followed by 1.9% in 2022 and 1.8% in 2023. This  the reduction in historic losses that can be car-
                         assumes oil prices averaging between $45 and 49  ried forward.
                         per barrel during the period.          All in all, Lukoil stands to lose only $78mn, or
                           Gazprom Neft will suffer the most, as the EPT  less than 1% of its EBITDA, in 2021 as a result of
                         system is applied at its largest greenfield project,  the proposed changes. As for Russia’s other main
                         the Novoportovskoye oilfield in the Arctic. The  oil producers, Surgutneftegas will take a $92mn,
                         field produced 7.7mn tonnes per year (tpy)  or 2.6% hit, to EBITA in 2021, whereas Tatneft
                         (155,000 bpd) of oil and condensate last year,  does not have any fields under the EPT regime.
                         equal to 17% of Gazprom Neft’s domestic out-  The MinFin is unlikely to get everything it
                         put last year.                       is asking for, given the EPT regime’s popularity
                           Gazprom Neft generated an extra $0.7bn  among Russia’s powerful oil lobby. However,
                         in EBITDA last year thanks to the EPT system  some tweaks will be made, given the significant
                         being applied at Novoportovskoye, VTBC esti-  budgetary shortfall Russia is facing. A compro-
                         mates. The project had some $3.7bn of accumu-  mise is likely to be reached with the Kremlin's
                         lated historic losses that Gazprom Neft was able  direct intervention, given how high the stakes
                         to use to reduce its tax base. VTBC forecasts that  are on either side. ™



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