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1995年,俄罗斯石油工业在极需大量外资的情况下,出台了《产品分成协议法》(俄文缩写СРП1,英文缩写PSA2)税制,以吸引外资。该税法与普通税法相比具有稳定、灵活等优点,其在超大与微小型油田和油价较低时期的应用能够对投资风险起到很好的补偿作用;俄《产品分成协议法》与许可证制度相互完善补充构成了该国石油工业相对稳定的税收体系,近10年来《产品分成协议法》在俄石油工业的应用取得了明显的效果。2003年,俄联邦政府对《产品分成协议法》的使用大加限制,这在很大程度上引起原计划在“产品分成”方案下开发的油气资源的重新分配。俄政府这一强制性的政治行为阻碍了本国石油工业的健康发展,也给国外的投资者带来了巨大的经济损失,不利于国际石油合作的顺利进行。
In 1995, the Russian oil industry introduced the “Product Sharing Agreement Law” (Russian abbreviation СРП1, abbreviation PSA2) in order to attract foreign investment when a large amount of foreign investment was needed. The tax law has the advantages of stability and flexibility compared with the general tax law. Its application in the ultra-large and micro-sized oil fields and in the period of low oil price can play a good compensatory role in the investment risk. The Russian “Product Sharing Agreement Law” and the permit Complementing the system complement each other constitute the relatively stable tax system of the country’s oil industry. In the past 10 years, the application of the Agreement on the Share of Products in the Russian petroleum industry has achieved remarkable results. In 2003, the Russian Federation severely restricted the use of the “Agreement on the Sharing of Products,” which largely contributed to the redistribution of oil and gas resources originally planned for development under the “product sharing” program. The obligatory political act of the Russian government has hindered the healthy development of the oil industry in our country. It has also brought huge economic losses to foreign investors and is not conducive to the smooth progress of international oil cooperation.