Open Joint Stock Company Gazprom

If a holder sells a Note during a current interest period, the accrued interest received inconnection therewith (Stückzinsen) will also be subject to 30% Zinsabschlagsteuer and 5.5% solidaritysurcharge, as above creditable against the personal or corporate income tax and the 30%Zinsabschlag-steuer and solidarity surcharge. Stückzinsen paid by a holder upon the purchase of aNote reduces the personal or corporate income tax base and, under certain circumstances, the taxablebase for the Zinsabschlagsteuer and solidarity surcharge.Non-Resident HoldersPayments of interest to persons who are not tax residents of Germany and have no connectionwith Germany other than the receipt of payments in respect of the Notes are in general exempt from theZinsabschlagsteuer and solidarity surcharge.If the interest from a Note that is kept or administered in a German securities deposit account bya German financial institution, which term includes a German branch of a foreign financial institution butexcludes a foreign branch of a German financial institution, is received by persons who are not residentsof Germany and who are taxable in Germany only with respect to certain German source income, andif, according to German tax law, such interest falls into a category of taxable income from Germansources (e.g., income effectively connected with a German trade or business) which is subject to alimited income tax liability on a special basis, the 30% Zinsabschlagsteuer and the 5.5% solidaritysurcharge are applicable but can be credited against the German personal or corporate income taxliability of such non-residents.Other TaxesGains realised by persons who are not tax residents of Germany from the sale or otherdisposition of Notes that are not held as part of a permanent establishment or fixed base in Germanywill not be subject to tax in Germany. No stamp, issue, registration, or similar taxes or duties will bepayable in Germany in connection with the issuance, delivery or execution of the Notes.EU Withholding TaxThe European Union is currently considering proposals for a new directive regarding the taxationof savings income. Subject to a number of important conditions being met, it is proposed that MemberStates will be required to provide to the tax authorities of another Member State details of payments ofinterest or other similar income paid by a person within its jurisdiction to an individual resident in thatother Member State, subject to the right of certain Member States to opt instead for a withholdingsystem for a transitional period in relation to such payments.91