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Mineral exploration and extraction activities are permitted only to those who
have an appropriate contract with the Republic of Kazakhstan, termed a subsurface user contract. The Tax Code offers alternative tax regimes for taxpayers involved in mineral exploration and extraction activities, which the legislation terms “subsurface users”.
Model 1 offers a regime under which the subsurface user is subject to all the
taxes which affect ordinary taxpayers (corporate income tax, social tax, vehicle tax, property tax, land tax, etc) and, in addition, certain specific taxes applicable to mineral extraction activities:
• Bonuses (both on signature of the contract and following a commercial discovery)
• Royalties
• Excess Profits Tax
• Rent Tax on Export of Crude Oil
Of these taxes, the first three existed prior to the 2004 tax changes, but the
reform package includes major changes to the way they operate which are described later in this article. The fourth, Rent Tax, is a completely new tax. This is also described in more detail below.
Royalties and Rent Tax apply to gross income and are deductible in calculating both corporate income tax ("CIT") and Excess Profits Tax. СГТ is deductible in computing Excess Profits Tax.
Model 2 offers a production sharing regime of the type familiar from other hydrocarbon provinces around the world. Though not explicitly confined to hydrocarbon extraction activities, the mechanism for allocating production between the State and the subsurface user is written with hydrocarbon liquid extraction activities in mind and may not be easily adapted to other kinds of minerals, including gas. Subsurface users which sign up to Production Sharing Agreements ("PSAs") are obliged to share production with the Republic in accordance with formulae set out in the PSA itself, and to the other taxes prescribed in tax legislation, excluding, however:
• Rent Tax on Export of Crude Oil
• Excise Tax on Crude Oil (including gas condensate)
• Excess Profits Tax
• Land Tax
• Property Tax
The gross income of the contractor for CIT purposes includes both cost recovery oil and the contractor's share of profit oil. The base for calculating the contractor's royalty obligation is the gross amount of crude oil produced before production sharing.
In 2003, the possibility of a third model was extensively discussed. This was to be based around a rent tax similar in concept to that discussed below, but the idea was abandoned, apparently following discussions with state oil company Kazmunaigaz.
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