surgutneftegas - public corporation

The right to receive dividends is provided to the shareholders comprising the shareholder register of OJSC “Surgutneftegas” (hereafter referred to as issuer) as of the date of making-up the list of shareholders entitled to participate in shareholders’ meeting pertinent to the adoption of the dividend payment resolution.

The effective legislation of the Russian Federation contemplates the exemption from taxes or  a reduced tax rate for the taxation of the dividends due to be paid
to the shareholders – co–op share funds and shareholders – foreign legal entities.

If the application of a reduced rate of the dividend withholding tax is sought we inform you of the list of documents that shall be submitted to the tax agent (issuer).

CO-OP SHARE FUNDS’ MANAGEMENT COMPANIES:

- certified extracts from the Rules of co–op share funds’ trust management, confirming co–op share funds’ registration in federal executive authority for securities market, co–op share fund name, co–op share fund type, full corporate name and location address of the management company, data on the license of the management company, full corporate name and location address of the specialized depository company, the validity of co–op share fund’s trust management contract, director general signature;

- certified copies of the amendments and supplements (registered in the federal executive authority for securities market) to the Rules of co–op share funds’ trust management, as for the above data.

- certified copy of the license issued by the federal executive authority to the management company for the right to manage the co–op share fund;

- original extract from a depot account statement as of the closing date of the issuer’s shareholder register with the information on share ownership of the management company and asset components of the particular co–op share fund, with specification of state registration number of the shares, their type and quantity;

- original reference of co–op share fund’s asset value as of the closing
date of the issuer’s shareholder register in the form adopted
by FCSM RF Regulation No. 03-41/ps dated 22.10.2003, and separate information on the issuer’s shares or the original full list of assets compiling the co–op share fund as of the closing date of the issuer’s shareholder register pursuant to the requirements of FCSM RF Regulation No. 04-5/ps dated 18.02.2004.

If the reference of co–op share fund’s asset value is signed by the CEO of the management company for a person responsible for accounting, the appropriate reference shall be submitted; if the reference of co–op share fund’s asset value is signed by a non-CEO of the management company, the letter of attorney for such operations shall be submitted.

Special requirements:

1) the copies submitted shall be accurate and readable; tied together and numbered; the authorized person certifies that the copy of the original document is true through stating the post title, putting personal signature, printing full name, and affixing a seal; if the copies are certified by a non-CEO of the management company the letter of attorney in the name of an authorized person shall be submitted.

2) original documents shall contain the post title, signature and printed name of the person responsible for the operation.

Foreign legal entities which do not operate via permanent representation in RF:

- the document (treasury tax note, certificate) confirming  the permanent residence of the foreign legal entity in a country with which the Russian Federation has an international treaty (agreement) for the avoidance of double taxation.

Special requirements to the document:

1. It shall be certified by a competent body of the foreign state defined in an appropriate international treaty (agreement) for the avoidance of double taxation.

2.  The text of the document shall specify the calendar year regarding which the permanent residence is confirmed and which corresponds to the year when dividends are paid, with reference to the ongoing international double taxation treaty (agreement).  

3. The document shall be dated by dividend payment year.

4. The document shall be legalized in a consular or diplomatic agency pursuant to the procedure established or apostilled by a competent body of the foreign state in accordance with The Hague Convention dated 05.10.1961.

5. The submitted copy of a specified document shall be certified by a Russian notary. Should the specified document be prepared in a language other than Russian, a notarized translation into Russian thereof shall be provided.

Foreign legal entities – residents of the Republic of Cyprus claiming
a reduced 5% withholding tax rate shall additionally submit:

- certified copies of sale and purchase agreements confirming the entity’s acquisition of the issuer’s shares in the amount equivalent to minimum USD100,000, or certified copies of broker’s reports in case of the issue’s shares acquisition by a professional participant of the securities market (broker) in the name of the client (a foreign legal entity);
 
- certified copies of the documents confirming the contractual payment of the issuer’s shares;

- original extract from a depot account statement of the Cyprus legal entity as of the closing date of the issuer’s shareholder register confirming the issuer’s share ownership of a foreign legal entity.

Foreign legal entities which are shareholders granting authority to Russian depositories (nominee holders) to receive dividends for them shall submit a letter of attorney.

The letter of attorney shall be valid by the moment of divided payment, and shall contain the date, place of issue, a list of particular powers, and validity period.

The submitted copy of a legalized and properly executed letter of attorney shall be certified by a Russian notary, and a notarized translation into Russian thereof shall be provided as well.