Rosneft and Gazprom are called "state" only for the red sense. Vladimir Milov: VAT growth means another decade without economic growth Why Gazprom does not pay taxes
The company argues with the FTS because of 300 million rubles
Gazprom graduated from the III quarter of the year with a loss of 9.2 billion rubles (according to RAS). Interestingly, despite so crying financial resultsTop managers received a good reward - 2.1 billion rubles.
Losses also did not prevent Gazprom to prepare for the 25th anniversary - 100 million rubles will be spent on it. Money will go to the organization "showing performances, concerts and other spectacular programs", as well as food in the State Kremlin Palace. Perhaps, like five years ago, Congratulations to Gazprom will come Sting, Andrea Bocelle, the Moral Code group, Diana Arbenina and other stars.
However, it is not necessary to accuse Alexey Miller in Transjirde. The company is able to save, especially when it comes to taxes. Now Gazprom is sued with the Interregional Inspectorate of the Federal Tax Service on the largest taxpayers No. 2. We are talking about the amount of 300 million rubles. It is 203 million taxes that Gazprom, according to the FTS, did not pay, the rest - penalties and fines.
As follows court documentsThe whole thing in two pipelines located in Siberia. Gazprom decided that they were trunk, and the FTS did not agree with this. The fact is that the main gas pipelines were tax breaks. In 2012, they were not taxed at all, and in 2013 the rate for them was reduced.
The court studied for a long time, which in Russia there are pipelines: a description of pipes and regulatory nuances is ranked 64 pages. And the result, the case won Gazprom (in August 2017).
FTS filed an appeal, the meeting was scheduled for December 21. This case is among the most important in the Gazprom report for the III quarter.
The share of the state in the authorized capital of Gazprom (taking into account indirect ownership) is 50%. And when the corporation is sued with the FTS, it turns out that the state is suing with himself.
Gazprom believes that the Tax Code is like a novel that can be interpreted in different ways. Did Anna Karenina cost from her husband? Was it worth paying taxes? These are questions to which it is difficult to find an answer.
The company writes in the reports: "Russian tax, currency and customs legislation allows various interpretations and is subject to frequent changes. Tax authorities may take a more rigid position in the interpretation of legislation and verify tax calculations. "
Practice shows: to register in the law all the variations are really impossible, despite the fact that our tax code is written in very detailed, - said legal company "Tax Help" Ilya Mokryshev.
According to him, many Russian companies have been about the trunk pipelines.
And most of them lost their affairs, unlike Gazprom, he noted.
According to the lawyer, this "situation is quite controversial."
Often tax authority Revises the situation in the back number, "said the lawyer. - that is, when the taxpayer submits the initial declaration, the tax authority at cameral check Does not make a claim. But he places claims, already when he holds departure check- after 3-4 years.
Because of this uncertainty of the company and write in their reports of "different interpretations" of the Tax Code.
So they can notify shareholders: despite the fact that they carefully lead tax and accountingThis does not guarantee the absence of claims on the results tax control, "the lawyer explained.
As told tax lawyer Sergey Shapovalov, for and against giant companies, fighting the best tax lawyers are fighting.
For Gazprom not a problem hire itself best specialists. Therefore, FTS has created a specialized inspection, where lawyers are working, which are also very well understood in such specific disputes.
By the way, only the Law Firm "Vegas Lex" this year concluded contracts with the structures of Gazprom by more than 40 million rubles.
There is a struggle against equals between tax and state corporation. SAMI weak side Here is a judge.
The dispute is specific and requires many highly specialized knowledge, which the judge does not have, "the lawyer said. - The judge wants to make a legitimate decision, but if he doubts, it is very likely that he can put budget interest in the head of the corner.
Our " national treasure"(How does Gazprom call himself) will not disappear - the company is trying on taxes all the time. In September, it was reported that Gazprom achieves tax exceptions. He asked to defrost for one of his projects the Institute of Consolidated Group of Taxpayers (CCN).
This mechanism appeared in 2012. Companies that are included in the group combine profits and losses. Total tax Decreases due to the inclusion in the group of unprofitable enterprises. In 2015, a moratorium on the creation of new CGN was established.
The size of dividends that go to the budget is also in no hurry to increase.
In 2015, the company adopted a dividend policy, which allows it to pay 17.5-35% of net profit in the form of dividends. At the same time, in the government for several years they have been wanted to increase dividends for state-owned companies up to 50% (under IFRS).
In 2018, the volume of investments will be 1 trillion 280 billion, and in 2019 - 1 trillion 400 billion ... - said in late November Chairman of the Board of the Company Alexey Miller at a meeting with the president. - this is the supply of gas to China on the "Eastern" route, the power supply "Power of Siberia", the arrangement of the Chayandinsky field, the construction of the Amur gas processing plant, in the end of 2019 the Turkish flow gas pipeline and the creation of gas transmission facilities in the Northern Corridor, to the North Western Russia for gas output from Yamal for consumers in Russian Federation And for supplies to export over the "Northern Flow".
As all the time representatives of Gazprom say, if you pay more to the state, there will not be enough money for all these large-scale construction sites (well, on corporate parties with prizes, but this is not pronounced). And 25 years - this is such an age when "groaning and rushing there, where dreams come true" (Gazprom's slogan), and you can still under the song Sting.
As follows from the last annual report Gazprom, in 2016, he paid taxes in the amount of 1.2 trillion rubles. In the form of dividends, the state got 95 billion rubles. The company's revenue for 2016 amounted to 3.9 trillion rubles.
Svetlana Basharova
Gazprom miners gas and oil - for this company pays tax on mineral mining (NPPI). IN tax Code The formula is prescribed - this tax pays "Gazprom". In the formula, several coefficients.
Sergey Shabolkin
private investor
On July 5, the State Duma adopted a bill in which he increased one of the coefficients to calculate the tax. If Gazprom continues to produce gas and gas condensate at the same level, and the price of oil will not change, the tax amount will increase.
Why raised the coefficient for Gazprom
Gazprom dividends need to be implemented to implement state programs. Since governmental structures are the holders of a large share package, they could make new candidates for the Board of Directors - new candidates would have taken decisions that the company's shareholder requires. But officials decided to get money through legislation, not corporate governance.
How will it affect profit
The final size of the NDPI affects not only an increased mining ratio: in the formula for calculating the NPPI, the price of oil of the Urals brand is taken into account. More expensive oil - more taxes.
In the 4th quarter of 2017, URALS oil cost approximately $ 57.12 per barrel, and July 9, 2018 - 75.23 dollars. If oil remains as expensive, then Gazprom will pay significantly more taxes than in 2017.
The management of Gazprom annually sends to dividends from 17.5% to 35% of profits for dividends. On the one hand, the state is counting on 50% of profits. On the other hand, the state will still receive additional money at the expense of taxes. Will now put pressure on Gazprom to pay 50% of profits - it is not clear.
How will this affect other oil and gas companies
In no way. State Duma increased the coefficient for companies involved in unified system Gas supply (ESG), Gazprom among them. The ESG is a pipe system for which gas is transported and stored.
What's next
Increased coefficient will be valid from September 1 to December 31, 2018. Next year, the Government will discuss the dividend policy of Gazprom. If the state does not agree with the company - it is possible to further increase the coefficient for mining. In short, Gazprom has the status "everything is difficult."
The State Duma adopted a law that provides new tax breaks for Rosneft and Gazprom projects.
In particular, the law provides Rosneft tax deduction NPPI for the self-control deposit and makes changes that will reduce NPPI on gas for joint ventures with Gazprom mines producing gas on Achimov deposits.
The law provides an opportunity to join consolidated group Taxpayers (CCN) organizations that are involved in the construction of the Amur Gas Processing Plant (Gazprom project).
The law establishes the zero VAT rate in relation to the pipeline pumping services in the cases provided by the international treaties of Russia, if Russia is recognized as a place of providing such services.
The law removes restrictions on the deadline for the start of application reduced rates NPPI during gas production on new marine deposits on the continental shelf, and also extends for 2018-2022. The action of the zero RTP rate during the extraction of conditioned ores of tin in the sections of the subsoil, fully or partially located in the Far Eastern Federal District.
The law allows for a decrease in the NPP, calculated in the extraction of gas condensate, on the value of the tax deduction due to the preparation of a wide fraction of light hydrocarbons in the processing of condensate.
In addition, the law exempts from taxation of income of Russian government agencies against which other countries sanctions apply if these revenues are obtained from the sale of shares and the shares of these government agencies. However, the benefits are valid when performing a number of conditions.
First, the benefit is used if, after the sale of shares, the share of the seller in the capital of the issuer is at least 50%. Secondly, the buyer should not be interdependent person with the seller. Thirdly, at the date of concluding an agreement on the transfer of rights, the state has the right to directly or indirectly dispose of more than 50% of the voting shares (shares) that make up the capital of the seller's organization. Fourth, on the date of sale of shares (shares), the seller's organization must at least a year directly or indirectly participate in the capital's capital, whose shares sells. At the same time, the share of such participation should be at least 50%.
The Board of Gazprom paid 2.1 billion rubles against the backdrop of a record for 19 years.
Members of the Board of Gazprom received a remuneration in the amount of 2.137 billion rubles for the first 9 months of 2017, the Company reported in the financial statement for RAS.
Compared last year, the earnings of top managers of the gas monopoly remained practically unchanged (+ 8 million rubles), and compared with 2015 increased by 22%, or 397 million rubles.
The bulk of the amount, as in the past year, accounted for award. Their size amounted to 1.467 billion rubles. The payment took place even though, according to the results of the reporting period, Gazprom became unprofitable for the first time in 19 years.
January-September of this year, a holding holding a monopoly right for the sale of Russian gas abroad, graduated from a loss of 9.205 billion rubles.
Quarterly losses from the Company were recorded before, however, minus 9 months for Gazprom became the first with the default 1998.
The reason for this result is not entirely clear, target \u003d "_ blank"\u003e notes the deputy director of the group of corporate ratings of Accra Vasily Tanurkov.
Revenue from gas sales increased by 8.8%, to 1.997 trillion rubles. Gross profit companies - by 4%, to 1.198 trillion rubles; Profit from sales - by 21%, to 232.9 billion rubles.
An essential jump occurred under the article "Other expenses", indicates Tanurkov: a year ago, 47 billion rubles left for these not certain spending, and in 9 months of the current - 387 billion rubles.
"Allegedly there could be a negative balance of exchange rate differences on currency assets and the obligations of the company," Alexey Kalachev argues the Finama analyst.
Clarity, according to him, will make reporting international standards (IFRS), which Gazprom publishes in the near future.
rusanalit. : Many thanks to everyone who fixed and adjusted my text about Gazprom. Gazprom will subscribe Russia? Nothing like this! As a result, I wrote it almost anew.Refused, for example, from 2005 and recalculated everything in 2008. It turned out very interesting. For example it turned out that
By paying 685 billion rubles in 2008, Gazprom received from the budget of subsidies - at the expense of low export duties and NPPI - by 650 billion rubles.
Those. In essence, Gazprom does not pay taxes at all! Interestingly, whether his "elephant" will publish.
since LJ Rusanalita is removed, I post the full article below
Gazprom will subscribe Russia? No - Russia will subscribe "Gazprom"! "
The total export capacity of the gas pipeline system through which it is possible to pump out the export of Gazprom gas (without Kazakhstan, Armenia and Georgia) is:
1. Ukrainian direction:
143.5 billion cubes - pure possible exports (formally more, up to 179 billion cubic meters - but for this you need to invest substantial funds in the modernization of the GTS of Ukraine).
2. Belarusian direction:
35 billion cubes - pure possible exports (incl. Yamal-Europe)
3. Turkish direction ("Blue Stream"):
16 billion cubes - Pure Possible Export
4. Latvian direction:
2 billion cubes - Pure Possible Export
5. Finnish direction
7 billion cubes - Pure Possible Export
Total, coincible in all five directions of pure possible exports beyond b. USSR (in European and Turkish directions): 203.5 billion cubes.
In 2008, the transit of Russian gas through the territory of Ukraine amounted to 119.6 billion cubic meters. Through Belarus - 51.4 billion cubic meters. According to the "blue stream" - 10 billion cubes. In Latvia - 0.7 billion cubes. In Finland - 4.9 billion cubes.
TOTAL: 186.6 billion cubes. With throughput in 203.5 billion cubes.
Conclusion No. 1: Gazprom's free export capacity was at 17 billion cubes of gas (rounded in favor of Gazprom).
It is so much in 2008 "Gazprom" could put on exports additionally, removing them from the domestic Russian market, where he put 287 billion cubic meters in that year. And then the first deception from Gazprom - it increases prices for all 287 billion cubes of gas (more precisely, taking into account the fact that the population and housing and communal services consume 27% of the gas - by 209 billion cubic meters) entering the Russian market - forgetting, What can in fact export no more than 9% of this volume. More lack of transport facilities.
Cumulative gas consumption of Europe (incl. Turkey) in 2008 amounted to 550.6 billion cubic meters. Now imagine that Gazprom set forth the target of 17.8 billion cubic cubes from the domestic market in this market. We believe: 17 billion cubes of gas are 3.1% of the total European gas consumption. You can sell them on this quite secured by the gas market, you can only enjoy your gas someone else, who does not want to leave there. How to push out someone else's gas from the European market? Only lower prices for your gas - i.e. Through dumping. But other gas sellers, wanting to keep the market, will dumping. On the other hand - what is 3.1% for the European market? But we look at and see: Qatar to push 30 billion cubic meters in 2009 (Qatar supplies liquefied natural gas, but we recalculated it to the equivalent simply natural) I had to sell them more than twice the Gazprom city price, on average 130-150 dollars for 1000 cubes.
The moment of the unwillingness of Europe increases the dependence on gas supplies from Russia can be omitted - it seems, having received a significant discount for the price, it would have experienced the growth of the share of Russian gas to 6% up to 35%.
But we assume that Gazprom could sell these 17 billion gas cubes in Europe without any discounts. Those. $ 308 per 1000 cubes (calculation is given below). Thus, he would help it from the sale of this additional volume of 5.2 billion dollars. And this is - but only in the first approximation - the size of the subsidies of Gazprom to the Russian economy.
Why in the first approximation? And because Gazprom has another not that mystery, but the fact that he prefers not to advertise - tax subsidies from the budget, primarily due to the underestimated (against the oil counterpart) of NPPI and low export duties. Calculate?
Export duty
Since the export price of gas is formed by the formula based on the price of oil for approximately 9-month prescription, then most of the average annual export gas price in 2008 is formed by the price of oil in the past 2007. Therefore, in its calculation, we will consider the price of 2008 gas and the price of non-oil 2007.
Under the average annual price for oilUrals. $ 69.3 per barrel (2007), the price of a ton of exported oil of this basic for Russian grade exports in 2007 amounted to $ 505.
The share of customs duties in it (calculated by the formula of the Ministry of Finance)
29.2+ (7.3 * (69.3-25)) * 65% \u003d $ 239.5 dollars.
According to its own data "Gazprom", the volume of gas sales to Europe in 2008 amounted to 184.4 billion cubic meters. m gas.Revenue from the sale of gas to Europe in 2008 amounted to 1430.5 billion rubles. Thus, 1000 cubes of gas were sold to Gazprom in 2008 to Europe at a price of 7770 rubles. The average annual ruble rate in 2008 amounted to about 25 rubles per dollar. Thus, the cost of 1000 cubes of gas amounted to 308 dollars. Or 61% of the cost of ton oil in 2007.
In logic, export duties per 1000 cubic gas should be the same 61% of the export duty on oil or $ 146 dollars ($ 239.5 * 61%).
According to the order of the State Code of the Russian Federation of December 11, 2003, N 1431 (in pursuance of the Decree of the Government of the Russian Federation of 19.08.2003 No. 507), from January 1, 2004, an exported customs duty rate is applied for gas in a gaseous state exported from the territory of the Russian Federation outside Member States of the Customs Union agreements, in the amount of 30 percent of the customs value,
Thus, at an average annual price for $ 308 exported to Europe for 1000 cubes, the export duty rate is 92.4 dollars. As we counted above, the "equilibrium" with oil rate of export duty on gas should be $ 146. Those. Dotation by the budget of the Russian Federation in favor of Gazprom in the export of those in 2008 to countries of foreign countries 184.4 billion cubes of gas amounted to: 184,4 m / 1000 * (146-92) \u003d 9.9 billion dollars.
NPPI.
In 2007, 492 million tons of oil (and gas condensate) were produced in Russia. Receipts from NPPI on oil amounted to 1,017 trillion in the same year. rub. Thus, the weighted average rate of NPPI amounted to 2067 rubles per ton of oil.
61% of 2067 rubles is 1261 rubles -it was such a NPP with 1000 cubes exported to far abroad Gaza was supposed to pay Gazprom with equal taxation with the oil industry . In reality, the NDPA rate amounted to 147 rubles.
Those. Dotation by the budget of the Russian Federation in favor of Gazprom with exports in 2008 to foreign countries of 184.4 billion cubic meters of gas amounted to: 184,4 million / 1000 * (2061-147) \u003d 353 billion rubles. or 16.1 billion dollars
Conclusion: Cumulative subsidies in favor of Gazprom on the part of the budget of the Russian Federation at the expense of underestimated export duties and the lowered NPPI amounted to 26 billion dollars.
The net profit of Gazprom in 2008 amounted to 771.38 billion rubles or about 31 billion dollars. Thus, Gazprom's profits before the income tax issued 1,014 trillion. rubles. Of which 650 billion rubles. ($ 26mld. * 25 rub.) - This is a subsidy on the part of the budget of the Russian Federation. Thus, the "dirty" profit of Gazprom in 2008 is 65% formed by subsidies from the budget of the Russian Federation.
Remember it - if Gazprom paid export duties and NPPIs on equal terms with oil workers, then his profit would be 3 times less, and the budget revenues of the Russian Federation were 650 billion rubles more.
Now let's remember that Gazprom in the ideal case could export 17 billion cubic cubes in the amount of 5.1 billion dollars in free gas pipelines. Of these, export duties would be 30% or 1.5 billion dollars. Those. From the sale of this volume Gazprom would have helped $ 3.6 billion, (from which "on the mind" would need to still remove transit costs). At the same time, he did not give these 17 billion cubes at all, and sold them in the domestic Russian market at a price of 1652.8 rubles per 1000 cubes (minus VAT and excise). Or 66 dollars, thus holding out the "clean" $ 66 * 17,8mld. / 1000 \u003d 1.1 billion dollars.
Those. Refusing exports in favor of the Russian market Gazprom lasted $ 3,6 billion .- $ 1,1 mm. \u003d $ 2.5M LD. dollars.
But as we remember, the taxes he has not been taxed at $ 26 billion dollars! Those. 10 times more!
Conclusion: In 2008, the net subsidies of the Russian budget in favor of Gazprom amounted to $ 23.5 billion.
So, as we see, I will not "Gazprom" you will reach the Russian economy, and everything is up to the opposite to the contrary - the budget of Russia will reach Gazprom for a huge amount. But at the same time, Gazprom is going to raise prices in Russia at times, arguing that he "subscribes" deliveries to the domestic market. Those. He wants not only to receive huge subsidies from the budget of the country, but also to receive additional enormous money from Russia - at least 418 billion rubles per year (calculation below).
In 2008, Gazprom paid taxes - 685.8 billion rubles. The budget of the Russian Federation subsidized Gazprom in 2008 for export duties and NPPI to 650 billion rubles. ($ 26mld. * 25 rub.).
As we see from the table below, in 2008 the prices of gas in the CIS and the Baltic States were 2000 rubles higher than domestic. Taking into account the fact that the supply of Gazprom to the economy agents (i.e., minus gas consumption by the population) made up 209 billion cubic meters of gas, Gazprom that his losses amounted to 418 billion rubles and this argues the increase Gas prices for Russia are many times. 418 billion rubles. - This is $ 14 billion at the current course. It is so much "Gazprom" wants to rescue annually additionally from the Russian economy by increasing the price of gas. And then, if the base for the prices of prices will be the prices of the CIS countries and the Baltic States, which are two more times lower than prices for long-term abroad.
Medium gas sales price (minus VAT, excise and customs duties), rub. For 1,000 cubic meters. m. :
Direction / year | 2007 | 2008 | ||
Russia | 1301,1 | 1652,8 | ||
Far | 5181,9 | 7757 | ||
CIS and Baltius | 2672,9 | 3693,9 | ||
But - Whatever it was, whether Gazprom has the opportunity to sell all 209 billion cubes of gas for export or not, it will sell them at the prices of long-term contracts or significantly lower - Gazprom has the full right to declare:
if a russian enterprises They will be able to buy gas according to the equestrocal prices grew at times, it means that everything is correct - because it is market prices.
Has full right? No matter how. Because it will be a purchase "with a pistol at the temple" - in the conditions of almost complete monopoly of Gazprom, consumers do not have freedom of choice, there is no main component - competition among suppliers. In order for the price of gas supplies to the internal market of Russia really Market, its gas to the consumer must offer several consumer competing suppliers. NOTE RECOMMENTS - no market price.
Let's understand - with an increase in prices for supplied on inside russian market Gas, Gazprom loses the only substantiation of its conservation as a single company as a monopoly. If, of course, you think that interests russian economy Above the interests of a separate company. After all, the export of gas can - how, say, it makes "Rosvooruchny" in the field of export of weapons - to carry out a single state-owned - to avoid the situation in which produced by several russian companies Gas will compete in the European market itself.
So, if Gazprom wants to raise prices for Russia to "equilibrium" with Europe - then Gazprom should be divided into several (no more than three, so as not to lose the effect of scale) parts, the "pipe" is derived into a separate state-owcture company "Transgaz" (By analogy with "Transneft"), and the export of gas should carry out a single state-term. And the main thing - Gazprom (more precisely, the companies to which it will be divided) must fully pay taxes in russian budgetBy refusing to subsidize the export duty and NPPI.
PS. And last - I just noticed.
So,
- As can be seen from the plate, the difference in the price of the Russian market and the market of the Baltic countries and the CIS market is 3693.9-1652.8 \u003d 2041.1 rubles per 1000 cubes of gas
- 23.5 billion dollars of the budget dotation of the Russian Federation Gazprom in 2008 on the average annual rate of 25 rubles per dollar 587,5 billion rubles
- To the Russian market in 2008, Gazprom put 287 billion cubes of gas
Calculation: 287mld. / 1000 * 2041.1 \u003d 585.8 billion rubles.
Those. To the Russian market in 2008 - taking into account the subsidies from the budget of the Russian Federation - Gazprom supplied gas exactly at the same price, as he did it to the Baltic countries and the CIS.
And the fact that the calculation came out practically "ruble ruble" suggests that there is an agreement between Gazprom and the Russian authorities for the fact that the real price of gas supplied to the Russian market should be equal to the markets for the Baltic and CIS market.
Note. All data - besides your own calculations of the author - taken from the Gazprom site:
http: //www.gazpromquestio ns.ru/index.php?id\u003d34 (foreign markets)
http: //www.gazpromquestio ns.ru/index.php?id\u003d35 (Russian market)
+
http://www.eegas.com/fsu_ r.htm (system of export gas pipelines)
Moscow, Nov 16 - RIA Novosti. The State Duma adopted a law that provides new tax breaks for Rosneft and Gazprom projects.
The document, in particular, provides "Rosneft" tax deduction on NPPI for the Samotlorian field and makes changes that will reduce the NPP on gas for joint ventures with Gazprom enterprises carrying out gas production at Achimov deposits.
The law also makes changes that provide an opportunity in 2017 to join the consolidated group of taxpayers (CCN) to organizations implementing the project for the construction of the Amur Gas Processing Plant (project "Gazprom"). Current legislation Mentioned a moratorium on registration in 2016-2017 changes to the contracts for the establishment of CCN related to the accession to such a group of new organizations.
The zero VAT rate is established in relation to the services for the transportation of natural gas by pipeline transport in cases provided for by international treaties of the Russian Federation, and the territory of the Russian Federation is recognized as a place of implementation of such services. This will allow, when providing such services to take to deduct VAT in Russia. In accordance with the current agreements during the transportation of the gas, this tax cannot be taken to deduct anywhere, explained earlier Deputy Minister of Finance of the Russian Federation Ilya Trunin.
NDPI
The law is removed by limitations on the limit periods of the beginning of the application of low NDPA rates during gas production at the new seats on the continental shelf, and also extended for 2018-2022 the zero NPPE rate during the extraction of conditioned ores of tin in the subsoil areas, fully or partially located on the territory of the Far Eastern Federal County. The document also admits a decrease in the NPP, calculated in the extraction of gas condensate, to the tax deduction due to obtaining with its processing a wide fraction of light hydrocarbons.
Help with sanctions
In addition, the income of Russian government agencies against which other countries are subject to sanctions from the sale of shares and shares. For this, it is proposed not to consider when determining tax base The income from the sale of shares (shares) received by the Organization, on the date of entering into the transfer of rights on them, was sanctions from foreign countries and organizations.
But this benefit will be valid while simultaneously performing a number of conditions. First, if after the implementation of shares, the share of their seller in the capital of their issuer is at least 50%. Secondly, the buyer is not an interdependent face with the seller. Thirdly, at the date of concluding a contract for the transfer of the rights of the Russian Federation, it has the right to directly or indirectly dispose of more than 50% of the voting shares (shares) constituting the Capital of the Seller's organization. Fourth, at the date of the implementation of shares (shares), the seller organization is at least a year directly or indirectly participates in the organization, whose shares are implementing. At the same time, the share of such participation is at least 50%.