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                                  LETTER No. VP-6-05/572@
OF THE MINISTRY OF THE RUSSIAN FEDERATION FOR TAXES
                     AND LEVIES
                    of July 21, 1999
    Concerning the Procedure for the Application of Federal Law No.
                       62-FZ of March 31, 1999

 In response to numerous inquiries concerning the procedure for the application of Federal Law No. 62-FZ of
March 31, 1999 "Concerning the Introduction of Amendments and Additions to the Law of the Russian
Federation "Concerning Tax on the Profit of Enterprises and Organizations"" to transactions involving new State
securities which were received by organizations prior to April 1, 1999 as a result of novation in respect of State
securities carried out in accordance with Regulation No. 1787-r of the Government of the Russian Federation of
December 12, 1998 "Concerning Novation in Respect of State Securities", the Ministry of the Russian Federation
for Taxes and Levies, with the agreement of the Ministry of Finance of the Russian Federation, advises as
follows.

Profit (loss) arising from the sale (redemption) of State securities received as a result of novation (GKOs,
OFZ-PDs, OFZ-FDs) in accordance with a report of the Bank of Russia on the results of the replacement of State
short-term non-coupon bonds and fixed and variable coupon income federal loan bonds with redemption periods
up to December 31, 1999 which were put into circulation before August 17, 1998 (exchangeable GKOs and
OFZs) with newly issued obligations (Appendices Nos. 6 and 7 to the Statute Concerning the Procedure for
Carrying Out Novation in Respect of State Short-Term Non-Coupon Bonds and Fixed and Variable Coupon
Income Federal Loan Bonds With Redemption Periods up to December 31, 1999 Which Were Put into
Circulation Prior to the Statement of the Government of the Russian Federation and the Central Bank of the
Russian Federation of August 17, 1998 by Means of Replacement Subject to the Agreement of Their Holders
With New Obligations and the Partial Payment of Monetary Resources of the Ministry of Finance of the Russian
Federation and the Bank of Russia of December 21, 1998, No. 258/375-T, with account taken of subsequent
amendments) shall be determined in accordance with the procedure which is established by Federal Law No.
62-FZ of March 31, 1999.

In this respect, for the purposes of determining the paid cost of State securities which are received as a result of
novation, monetary resources which reduce an investor's actual expenditures on the acquisition of exchangeable
GKOs and OFZs shall include payments in the form of monetary resources and balances resulting from the
substitution of new obligations for OFZ-FDs, OFZ-PDs and GKOs which are indicated after table 2 in line items
1, 3, 4 and 5 of Appendices Nos. 6 and 7 to the above-mentioned Procedure.
Class I State Advisor of the Tax Service       V.A. Pavlov




     Category: Corporat.tax                    Date of approval by ministry of Justice:
     Data start: July 21 ,1999                    Ministry of Justice registry number:
     Data end:                                                          Type Version: Current




LETTER VP-6-05/572@

				
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