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EY-Global-oil-and-gas-tax-guide-2014

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Kazakhstan<br />

283<br />

Volume of annual <strong>oil</strong> production, including <strong>gas</strong> condensate,<br />

for each calendar year (thous<strong>and</strong> tons)<br />

MET<br />

<strong>2014</strong><br />

Up to 7,000 inclusively 13%<br />

Up to 10,000 inclusively 15%<br />

Over 10,000 18%<br />

These rates are reduced by 50% if the production is processed domestically in<br />

Kazakhstan either by the producer or by a purchaser. There are special rules for<br />

the calculation of <strong>tax</strong> bases in such cases.<br />

In the case of natural <strong>gas</strong> that is exported, a flat rate of 10% applies. If the <strong>gas</strong><br />

is sold to the domestic Kazakhstan market, rates are reduced to between 0.5%<br />

<strong>and</strong> 1.5% depending on the level of annual production.<br />

Bonuses<br />

Subsurface users are expected to pay two types of bonus:<br />

• Signature bonus<br />

• Commercial discovery bonus<br />

Signature bonus<br />

The signature bonus is a lump-sum amount paid by a subsurface user for the<br />

right to use the subsurface.<br />

For <strong>oil</strong> exploration contracts, the bonus is a fixed amount of 2,800 MCI, 1 which<br />

is equivalent to KZT 5,185,600. For <strong>oil</strong> production contracts, where reserves<br />

have not been approved, the bonus is a fixed amount of 3,000 MCI, which is<br />

equivalent to KZT 5,556,000. Where reserves have been approved, the bonus<br />

is calculated by a formula that applies a rate of 0.04% to the approved reserves<br />

<strong>and</strong> 0.01% to the provisionally approved reserves, but not less than 3,000 MCI.<br />

For production contracts, the signature bonus should not be less than the<br />

amount of the commercial discovery bonus.<br />

Commercial discovery bonus<br />

The commercial discovery bonus is a fixed payment paid by subsurface users<br />

when a commercial discovery is made on the contract territory.<br />

The basis for calculation of the commercial discovery bonus is defined as the<br />

value of the extractable minerals duly approved by the competent State<br />

authorities. The value of the mineral resources is determined using the market<br />

price established at the International (London) Petroleum Exchange in Platts.<br />

The rate of the commercial discovery bonus is fixed at 0.1% of the value of<br />

proven extractable resources.<br />

Corporate income <strong>tax</strong><br />

CIT is applied to all companies at the rate of 20% of <strong>tax</strong>able income previous<br />

years. Taxable income is calculated as the difference between aggregate annual<br />

income (after certain adjustments) <strong>and</strong> statutory deductions.<br />

Deductions<br />

All expenses incurred by a <strong>tax</strong>payer in carrying out activities that are directed<br />

at the receipt of income are deductible for the purpose of determining <strong>tax</strong>able<br />

income. Examples of expenses that are allowed for deduction can be found<br />

below (but this list is not exhaustive):<br />

• Interest expense (within limits)<br />

• Contributions to the decommissioning fund; the procedure for making such<br />

contributions <strong>and</strong> the amount to be established in the subsurface use<br />

contract<br />

1 The monthly calculation index (MCI) is KZT1,852 as of 1 January <strong>2014</strong>.

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