225. The taxpayers of Russian mineral resource use tax are mineral resource users, that is, units that must obtain permission to use mineral resources in the following ways (Article 18 of the Tax Law) and individual owners (Article 26).

Hereinafter referred to as tax) taxpayers: (1) Unless otherwise provided for in the Tax Law, survey and explore mineral lands and mine minerals in the territories of Russia’s neighboring states, their continental shelves and/or special economic zones; (2) Construction and

Underground facilities not related to mining; Except for the circumstances specified in paragraph 4 of Part 2 of this Article, the use of underground facilities not related to mining.

Whether or not there is a license to use corresponding types of mineral resources is the basis for identifying users of mineral resources as taxpayers.

226. Non-taxpayers under certain circumstances are listed as one of the following types of users according to the documents issued by the national mineral resources fund management agency or the land commission agency, and are not taxpayers: (1) In the property owned, occupied or leased by them

On land blocks, with the goal of directly satisfying one's own needs, mining common minerals and/or groundwater in accordance with prescribed procedures (without selling mineral raw materials or using them to manufacture products, and not using the above-mentioned minerals or groundwater for production and meeting industrial needs)

Land block owners, occupiers or lessees, and those who use groundwater to maintain lamination; (2) carry out regional geological and geophysical exploration projects, geological surveys, other geological projects for comprehensive research on underground resources, earthquake prediction and volcanic activity research

Geological engineering, engineering geological survey, paleontological research, earth ecological research, groundwater dynamic monitoring, and other mineral resource users who do not substantially damage the integrity of mineral resources; (3) Obtain mineral resource blocks and use them to construct scientific

, users of mineral resources in special protected geological projects of cultural, aesthetic, health care or other social significance (scientific research and training ranges, geological reserves, restricted areas, natural relics, rock caves and other underground caves); (4) Obtaining mineral resource areas

blocks, users of mineral resources used to protect the state reserves of the Russian Federation.

The users of mineral resources referred to in paragraphs 2 to 4 of this part refer to taxpayers who are not taxpayers in the use of such mineral resources.

227. If the following stipulations are stipulated in the license, the taxable objects of Russia's underground resource use tax will be deemed to be taxable if they obtain the right to use underground resources, use mineral resources, and/or specific events occur: (1) Those who obtain mineral resources

Exclusive right to use, including mineral mining rights (one-time payment - dividends); (2) as agreed in the license, certain events occur, including the start of mining (one-time payment - dividends); (3) as

Survey, evaluation and/or exploration rights obtained as part of the exclusive mining rights of minerals (periodic payments - leasing); (4) mining of minerals (periodic payments - royalties); (5) construction and (

or) use of underground facilities not related to mining (regular payments).

228. The tax base of Russia’s mineral resources use tax (1) The tax base is determined by the taxpayer according to each type of use of mineral resources and the type of mineral raw materials mined.

(2) During the survey, evaluation and exploration of mineral deposits, the tax base is determined based on the area of ??the licensed block where the taxpayer has the right to carry out such business activities, after deducting the refunded part.

(3) When mining mineral raw materials, the tax base is determined based on the cost of mining raw materials calculated from the mining volume and sales price during the final accounting period.

In this case, the above price does not include value-added tax, consumption tax, and service charges for delivering the mineral raw materials to the purchaser.

If a taxpayer sells mineral raw materials to interconnected buyers for further processing, or for processing with raw materials, or for free for industrial processing, or for its own use, the cost of the mineral raw materials must be determined based on the market price.

The tax base is as defined in Article 53 of this Law (excluding value added tax, excise tax and service charges for the delivery of mineral raw materials from the producer’s warehouse or from shipping stations, ports and terminals to the buyer in accordance with the terms of the contract).

When mining precious metals, the tax base is determined based on the output of refined precious metals and the sales price of refined precious metals (if precious metals are sold to the State Fund of Precious Metals and Gemstones of the Russian Federation, the sales price will be determined according to the procedures prescribed by the Government of the Russian Federation).

In this case, the above price does not include delivery service charges from the refinery to the recipient of the refined metal.

When users of mineral resources export and sell mineral raw materials, the amount of tax paid shall be determined based on the export sales price, deducting consumption tax, customs taxes and export freight.

Export freight includes transportation and transshipment fees, mixing and canning fees, loading and unloading fees, port service fees, freight charges and agency service fees.

If the losses incurred during mining exceed the standards stipulated in the annual mining project plan, and the standards are separately formulated for each mineral raw material mined by the taxpayer in consultation with the national mining supervision agency, the tax base shall be mentioned here.

The cost level of mining losses is calculated based on the average sales price of mineral raw materials in the final accounting year (excluding value-added tax, consumption tax and service fees for shipment to the buyer).