The draft law on taxing national natural resources provides for introduction, as of 2011, of new tax rates to be applied to extracted national natural resources. Compared to 2010, the tax rate would be over four times higher. We believe that the proposed tax increase is unjustified and unprecedented and the additional budget revenues estimates are unsubstantiated. Higher tariffs would be detrimental to mineral extraction companies, which are already facing difficulties. The revenue collection data show that increased tax rates which took effect at the beginning of 2010 did not answer the purpose. Therefore, we propose that the tax rates for national natural resources be brought back to the 2009 level.
In Article 2 of the draft bill a change of the tax period for taxes on national natural resources is proposed: instead of the currently applied calendar year period, taxes would be paid every three months. The change of the tax period frequency would not only require additional budgetary funds but would also increase the administrative burden for tax payers. As the tax is paid on the quantities of extracted and not of sold resources, a shorter tax period would have a strongly negative impact on enterprises which fail to realize extracted resources fast enough. We propose that the currently effectual calendar year tax period be retained.