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Issues reviewed by the Tax Code implementation Project Office
In August 2026, the Project Office reviewed, among others, the following issues:
1. Mineral extraction tax rates for crude oil[1]
The current version of Art. 778 of the Tax Code provides for new mineral extraction tax rates for crude oil from 1 January 2027 as part of a tax reform aimed at consolidating the tax burden.
At the meeting held on 10 August 2026, a representative of the State Revenue Committee explained that the rates provided by the Tax Code were calculated on the assumption that the rent tax and export customs duty (“ECD”) would be abolished. However, the ECD on crude oil exports, approved by an order of the Ministry of Trade, remains in force, which may effectively result in the ECD being charged twice. As the launch of the common EAEU market for crude oil and petroleum products has been postponed, the relevant Tax Code provisions should be aligned with the revised launch timeline.
Accordingly, amendments to the Tax Code are expected.
2. PIT treatment of discounts on debt securities[2]
According to the general definition in the Tax Code, a discount constitutes interest income. However, upon redemption of a security, it is effectively treated as a capital gain even though no sale takes place. To eliminate this legal inconsistency, it was proposed to revise Art. 378 of the Tax Code and continue treating the discount arising upon redemption as interest income on debt securities.
The need for a consistent approach to taxing income from debt instruments was supported. The relevant provisions of the Tax Code will be clarified.
3. Updating bylaw for the application of the zero mineral extraction tax rate[3]
Following the 26th meeting of the Project Office, the Ministry of Industry and Construction was instructed to clarify Government Resolution No. 1102 dated 18 December 2025, which specifies the criteria for low-profitability solid mineral deposits and the procedure for determining their profitability. The clarification is required to update the bylaw for the application of the zero mineral extraction tax rate under the Tax Code.