Circular No. 61 TC/TCT GUIDING THE TAXATION AND PROCEDURES FOR THE COLLECTION AND PAYMENT OF TAXES IN RELATION TO THE JOINT VENTURE AGREEMENT ON THE DISTRIBUTION OF PRODUCTS FROM THE DA HUNG OIL FIELD

CIRCULAR

GUIDELINES ON TAXES AND PROCEDURES FOR THE COLLECTION AND PAYMENT OF TAXES UNDER THE AGREEMENT ON THE SHARING OF MINERAL PRODUCTS FROM THE DAIHUNG FIELD

BASED ON THE PROVISIONS OF LAWS AND ORDINANCES ON TAXES IN VIETNAM; BASED ON THE FOREIGN INVESTMENT LAW OF VIETNAM; BASED ON THE TAX REGULATIONS AND TERMS OF THE AGREEMENT ON THE SHARING OF MINERAL PRODUCTS FROM THE DAIHUNG FIELD SIGNED ON APRIL 15, 1994, THE MINISTRY OF FINANCE ISSUES DETAILED GUIDELINES ON TAXES AND PROCEDURES FOR THE COLLECTION AND PAYMENT OF TAXES UNDER THE AGREEMENT ON THE SHARING OF MINERAL PRODUCTS FROM THE DAIHUNG FIELD AS FOLLOWS:

I. SCOPE OF APPLICATION

1. THIS CIRCULAR APPLIES TO FOREIGN ORGANIZATIONS AND FOREIGN COMPANIES PARTICIPATING IN THE AGREEMENT ON THE SHARING OF MINERAL PRODUCTS FROM THE DAIHUNG FIELD (HEREINAFTER REFERRED TO AS "THE AGREEMENT"), INCLUDING:

- THE ZARUBEZHNEFT UNION PARTICIPATING IN THE AGREEMENT AS A PARTY JOINING WITH THE VIETNAMESE GOVERNMENT TO FORM THE "JOINING PARTY" AT THE AGREEMENT (HEREINAFTER REFERRED TO AS "THE FOREIGN JOINING PARTY").

- FOREIGN COMPANIES BHPP, PETRONAS CARIGALI (CARGALI), TOTAL VIETNAM (TOTAL), DAIHUNG OIL DEVELOPMENT (JAPAN) LTD (SUMI TOMO) PARTICIPATING IN THE AGREEMENT AS FOREIGN CONTRACTORS.

2. REGULATIONS AND GUIDELINES ON TAXES FOR THE VIETNAM OIL AND GAS CORPORATION AS THE VIETNAMESE JOINING PARTY AND AS A CONTRACTOR; IN THE CASE WHERE THE VIETNAMESE GOVERNMENT COLLECTS MINERAL RESOURCES TAX IN THE FORM OF CRUDE OIL, SEPARATE GUIDELINES WILL BE ISSUED.

3. IN THIS CIRCULAR, THE TERM "TAXPAYER" MAY REFER TO THE "FOREIGN JOINING PARTY" OR THE "FOREIGN CONTRACTOR," OR INCLUDE BOTH THE "FOREIGN JOINING PARTY" AND THE "FOREIGN CONTRACTOR," DEPENDING ON THE SPECIFIC SITUATION.

1. Export duties, import duties, and value-added tax:

1. MINERAL RESOURCES TAX.

EACH FOREIGN COMPANY FORMING A CONTRACTOR IS OBLIGATED TO PAY THE MINERAL RESOURCES TAX TO THE VIETNAMESE STATE AS FOLLOWS:

1.1 METHOD OF DETERMINING THE MINERAL RESOURCES TAX:

ACCORDING TO THE PROVISIONS OF THE AGREEMENT, THE AMOUNT OF MINERAL RESOURCES TAX IS DETERMINED AS FOLLOWS:

Where:

- THE QUANTITY OF OIL SUBJECT TO MINERAL RESOURCES TAX IS THE ACTUAL QUANTITY OF OIL (MEASURED IN BARRELS) TRANSFERRED TO THE HANDOVER POINT IN THE QUARTER FOR WHICH THE TAX IS CALCULATED.

- THE RATE OF MINERAL RESOURCES TAX IS DETERMINED BASED ON THE AVERAGE DAILY QUANTITY OF OIL SUBJECT TO MINERAL RESOURCES TAX IN THE QUARTER FOR WHICH THE TAX IS CALCULATED, USING A PROGRESSIVE SCALE AS FOLLOWS:

QUANTITY OF OIL SUBJECT TO TAX (BARRELS/DAY)TAX RATE (%)

- UP TO 100,000 BARRELS25

- FROM THE 100,001ST TO THE 200,000TH BARREL35

- FROM THE 200,001ST BARREL AND ABOVE45

(THE NUMBER OF DAYS OF PRODUCTION IN THE QUARTER IS THE NUMBER OF DAYS IN THE CALENDAR THAT PRODUCTION ACTIVITIES ARE CONDUCTED; IT DOES NOT INCLUDE DAYS OF STOPPAGE OF PRODUCTION FOR ANY REASON).

- THE TAXABLE PRICE IS THE WEIGHTED AVERAGE ACTUAL SELLING PRICE PER BARREL OF OIL (IN US DOLLARS) OF EACH TAXPAYER IN THE QUARTER FOR WHICH THE TAX IS CALCULATED, UNDER THE CONDITIONS OF FOB OR FIP (PRICE AT PIPELINE DELIVERY POINT) AT THE HANDOVER POINT (TAX SETTLEMENT IS BASED ON THE ACTUAL PRICE).

IF THE TAXPAYER SELLS OR DISPOSSESSES CRUDE OIL ON OTHER BASIS THAN THE ABOVE (DOES NOT SELL CRUDE OIL OR SELL AT FOB OR FIP PRICES), THE TAX AUTHORITY WILL DETERMINE THE TAXABLE PRICE ACCORDING TO THE PRINCIPLE STATED ABOVE ON THE DAY OF "BILL OF LADING" (THE DATE STATED ON THE BILL OF LADING FOR EACH CRUDE OIL TRANSPORTATION TRIP AT THE HANDOVER POINT) AFTER CONSULTING THE VIETNAM OIL AND GAS CORPORATION.

IF THE TAXPAYER SELLS OIL WITHOUT COMPLYING WITH THE "ARM'S LENGTH TRANSACTION" REQUIREMENTS OR INTENTIONALLY SELLS AT A LOW PRICE, THE TAXABLE PRICE WILL BE DETERMINED ACCORDING TO THE PRINCIPLES PROVIDED IN THE AGREEMENT FOR DETERMINING THE MARKET PRICE IN SUCH CASES. WHILE AWAITING THE DECISION ON THE MARKET PRICE FOR THIS CASE, THE TAX AUTHORITY WILL TEMPORARILY DETERMINE THE TAXABLE PRICE AFTER CONSULTING THE VIETNAM OIL AND GAS CORPORATION. ANY DIFFERENCE BETWEEN THE TEMPORARY DETERMINED PRICE BY THE TAX AUTHORITY AND THE MARKET PRICE DETERMINED ACCORDING TO THE AGREEMENT WILL BE ADJUSTED IN EACH TAX SETTLEMENT PERIOD.

EXAMPLE: IN THE QUARTER FOR WHICH THE TAX IS CALCULATED, THE TOTAL ACTUAL QUANTITY OF OIL IS 11,700,000 BARRELS.

NUMBER OF DAYS OF PRODUCTION IN THE QUARTER: 78 DAYS

QUANTITY OF OIL SUBJECT TO MINERAL RESOURCES TAX TO BE PAID IN THE QUARTER:

(100,000 BARRELS X 25% X 78 DAYS) + (50,000 BARRELS X 35% X 78 DAYS) = 3,315,000 BARRELS

1.2 TAXPAYERS OF THE MINERAL RESOURCES TAX AND PROCEDURES FOR THE COLLECTION AND PAYMENT OF THE MINERAL RESOURCES TAX:

a- TAXPAYERS OF THE MINERAL RESOURCES TAX:

FOREIGN CONTRACTORS ARE TAXPAYERS OF THE MINERAL RESOURCES TAX, CORRESPONDING TO THEIR SHARE IN THE AGREEMENT.

b- PROCEDURES FOR THE COLLECTION AND PAYMENT OF THE MINERAL RESOURCES TAX:

THE MINERAL RESOURCES TAX IS TEMPORARILY SUBMITTED MONTHLY AND SETTLED QUARTERLY (QUARTER ACCORDING TO THE GREGORIAN CALENDAR) AS FOLLOWS:

b1- MONTHLY TEMPORARY SUBMISSION:

THE AMOUNT OF MINERAL RESOURCES TAX TEMPORARILY SUBMITTED MONTHLY BY EACH FOREIGN CONTRACTOR IS 20% OF THE VALUE OF THE INVOICE OF EACH SHIPMENT OF THE CONTRACTOR DISTRIBUTED IN THE MONTH (OR 20% OF THE MARKET PRICE IN THE CASE WHERE THE CONTRACTORS DISPOSE OF CRUDE OIL ON OTHER BASIS).

- NO LATER THAN THE FIRST 5 DAYS OF EACH MONTH, FOREIGN CONTRACTORS MUST COMPLETE THE SUBMISSION OF THE MINERAL RESOURCES TAX FOR THE PREVIOUS MONTH AND SEND TO THE TAX AUTHORITY THE TAX RETURN FORM (ATTACHED MODEL 1) ALONG WITH A COPY OF THE TAX PAYMENT RECEIPT.

IF FOREIGN CONTRACTORS DO NOT SEND THE TAX RETURN FORM TO THE TAX AUTHORITY WITHIN THE TIME LIMITATED, THE TAX AUTHORITY HAS THE RIGHT TO DETERMINE THE AMOUNT OF MINERAL RESOURCES TAX, ISSUE A TAX NOTICE TO THE FOREIGN CONTRACTORS, AND FOREIGN CONTRACTORS MUST PAY THE FULL AMOUNT OF TAX LISTED IN THE TAX NOTICE TO THE NATIONAL TREASURY DESIGNATED BY THE TAX AUTHORITY WITHIN 3 DAYS FROM THE DATE OF RECEIVING THE NOTICE.

b2- QUARTERLY SETTLEMENT:

- NO LATER THAN 30 DAYS AFTER THE END OF THE QUARTER, FOREIGN CONTRACTORS MUST FILE AND SEND THE TAX RETURN FORM OF THE PREVIOUS QUARTER TO THE TAX AUTHORITY (ATTACHED MODEL 2) SO THAT THE TAX AUTHORITY CAN SETTLE THE OFFICIAL AMOUNT OF MINERAL RESOURCES TAX TO BE PAID BY FOREIGN CONTRACTORS IN THE PREVIOUS QUARTER.

- When settling quarterly income tax, if the monthly provisional tax paid exceeds the actual tax payable for the quarter, the excess tax will be offset against the tax due for the next payment period. In cases where there is no subsequent payment period, the tax authority shall process the refund of the excess tax to foreign contractors; if the monthly provisional tax paid is less than the actual tax payable for the quarter, then within three days from the date of receiving the notification of quarterly tax settlement, foreign contractors must pay the outstanding tax to the State Treasury and send a copy of the payment receipt to the tax authority.

Beyond this deadline, if foreign contractors have not submitted their resource tax declaration forms to the tax authority, the tax authority has the right to determine the amount of resource tax payable for the quarter, issue a tax notice to foreign contractors clearly stating the determined tax amount, the monthly provisional tax paid, the excess tax to be offset against the next payment period, or the additional tax to be paid. Within three days from the date of receipt of the notice, foreign contractors must pay the outstanding tax according to the tax authority's notice. The officially determined resource tax payable for the quarter will be settled at the end of the fiscal year.

- Within thirty days from the date of receiving the quarterly resource tax declaration forms from foreign contractors, the tax authority is responsible for issuing a quarterly tax settlement notice to foreign contractors (in accordance with Form No. 3 attached).

2) Income Tax:

2.1 Taxpayers and Taxable Income:

- Each company forming part of a foreign contractor is a taxpayer for income tax.

- The income derived from oil and gas activities and incidental income (if any) of each foreign contractor is taxable income.

2.2 Calculation of Income Tax: Income Tax = Taxable Income x Tax Rate

2.3 Determination of Taxable Income:

a. Income from Oil and Gas Activities:

Taxable income is determined as follows:

Where:

- Actual oil production and resource tax oil quantity are determined as specified in Part II, Clause 1.1 of this Circular.

- The cost recovery oil quantity (per quarter) is determined based on the oil and gas activity costs that need to be recovered and the average market price per barrel of oil in the previous quarter before the tax quarter, using the formula:

(In cases where the cost recovery oil quantity exceeds 35% of the actual oil production in the tax quarter, the cost recovery oil quantity for the tax quarter will be set at 35% of the actual oil production in the tax quarter, and the excess cost recovery oil quantity will be carried over to the next quarter).

- The tax base price is the weighted average actual market price received by each contractor during the tax period (tax settlement is based on actual prices).

In cases where the contractor determines the income tax base price based on other criteria (not selling oil), the tax authority will determine the tax base price based on the market price at the date of the bill of lading after consulting the Vietnam Oil and Gas Corporation.

In cases where taxpayers sell oil not in accordance with "arm's length transactions" or intentionally sell at low prices, the tax base price will be determined according to the principles stipulated in the contract for determining market prices in such cases. Pending the determination of the market price for this case, the tax authority will temporarily determine the tax base price after consulting the Vietnam Oil and Gas Corporation. Any difference arising between the temporarily determined tax base price by the tax authority and the market price determined according to the contract provisions will be adjusted in each tax settlement period.

b. Incidental Income:

Incidental income includes income generated from activities outside oil and gas activities as specified in the Contract.

2.4 Income Tax Rate:

The income tax rate is 47% (forty-seven percent).

2.5 Collection and Payment of Income Tax:

Income tax is provisionally paid quarterly and finalized after the end of the tax year (calendar year) as follows:

a. Quarterly Provisional Payment:

- By the thirtieth day of each quarter, taxpayers must complete the provisional payment of income tax for the previous quarter and submit the income tax declaration form (in accordance with Form No. 4 attached) along with a copy of the payment receipt to the tax authority.

Beyond this deadline, if foreign contractors have not submitted their income tax declaration forms to the tax authority, the tax authority has the right to determine the amount of income tax, issue a tax notice to foreign contractors, and within three days from the date of receipt of the notice, foreign contractors must pay the full amount of tax stated in the tax authority's notice to the designated State Treasury.

b. Annual Tax Settlement

- Within ninety days from the end of the tax year (calendar year), foreign contractors must declare and submit the annual income tax declaration form (in accordance with Form No. 5 attached) to the tax authority.

Beyond this deadline, if foreign contractors have not submitted their annual income tax declaration forms to the tax authority, the tax authority has the right to determine the amount of income tax payable for the year, issue a tax notice to foreign contractors clearly stating the determined tax amount, the quarterly provisional tax paid, the excess tax to be offset against the next payment period, or the additional tax to be paid. Within three days from the date of receipt of the notice, foreign contractors must pay the outstanding tax according to the tax authority's notice. The officially determined income tax payable for the tax year will be settled during the tax settlement period.

- Within forty-five days from the date of receiving the annual income tax declaration forms from foreign contractors, the tax authority is responsible for conducting the tax settlement and issuing a tax settlement notice to foreign contractors.

- When settling annual taxes, if the total provisional tax payments for each quarter of the year exceed the tax payable for the year, the excess tax paid will be deducted from the tax payable for the next tax period; if there is no subsequent tax period, the tax authority shall process the refund of the excess tax paid to foreign contractors. If the provisional tax payments for each quarter of the year are less than the tax payable for the year, the foreign contractor must pay the outstanding tax within three days from the date of receiving the annual tax settlement notice to the State Treasury and submit a copy of the tax payment receipt to the tax authority.

3) Tax on profit repatriation

3.1 Taxpayers and liable objects for tax on profit repatriation

Foreign participants and foreign contractors are taxpayers for tax on profit repatriation.

The portion of profit repatriated out of Vietnam and the portion of profit retained outside Vietnam are liable objects for tax on profit repatriation.

3.2 Method of determining taxable profit

Where:

- Dividends and interest income:

+ For foreign contractors, it is the taxable income determined in Part II, Clause 2.2 of this Circular.

+ For ZARUBEZHNEFT, it is the share of oil profits distributed (in USD) as stipulated in the Contract.

- Profit retained in Vietnam:

It is the portion of profit determined as the taxpayer has utilized in Vietnam or has not yet transferred out of Vietnam in accordance with current laws.

3.3 Tax rate for tax on profit repatriation

- Foreign contractors pay tax on profit repatriation at a rate of 10% of the taxable profit.

- Foreign participants (ZARUBEZHNEFT) pay tax on profit repatriation at a rate of 5% of the taxable profit.

3.4 Collection and payment system for tax on profit repatriation

Tax on profit repatriation is provisionally paid quarterly and officially settled after the end of the tax year.

a- Quarterly provisional payment:

- The amount of tax on profit repatriation provisionally paid quarterly is determined based on the portion of profit repatriated out of Vietnam and the portion of profit retained outside Vietnam generated during the tax quarter and the tax rate for tax on profit repatriation as prescribed in Point 3.3.

- At the latest within the first 30 days of each quarter, the taxpayer must complete the payment of the tax on profit repatriation provisionally paid in the previous quarter and submit to the tax authority a tax declaration form for tax on profit repatriation (attached Form No. 6) along with a copy of the tax payment receipt.

If the taxpayer fails to submit the tax declaration form for tax on profit repatriation to the tax authority within the above time limit, the tax authority has the right to assess the tax on profit repatriation, issue a tax notification to the taxpayer, and the taxpayer must pay the full amount of tax indicated in the tax notification issued by the tax authority to the State Treasury designated by the tax authority within three days from the date of receipt of the notification.

b- Annual tax settlement

- At the latest within 90 days from the end of the year, the taxpayer must declare and submit the tax declaration form for tax on profit repatriation of the previous year to the tax authority (attached Form No. 7).

If the taxpayer fails to submit the tax declaration form for tax on profit repatriation to the tax authority within the above time limit, the tax authority has the right to assess the tax on profit repatriation payable for the year, issue a tax notification to the taxpayer specifying the assessed tax, the provisional quarterly tax payments, the excess tax to be offset against the next tax period or the additional tax to be paid. Within three days from the date of receipt of the notification, the taxpayer must pay the outstanding tax as specified in this notification. The final tax on profit repatriation payable for the tax year will be settled during the annual tax settlement period.

- At the latest within 45 days from the date of receipt of the tax declaration form for tax on profit repatriation submitted by the taxpayer, the tax authority is responsible for settling the tax and issuing a tax settlement notification to the taxpayer.

- When settling annual taxes, if the provisional tax payments for each quarter of the year exceed the tax payable for the year, the excess tax paid will be deducted from the tax payable for the next tax period; if there is no subsequent tax period, the tax authority shall process the refund of the excess tax paid to the taxpayer. If the provisional tax payments for each quarter of the year are less than the tax payable for the year, the taxpayer must pay the outstanding tax within three days from the date of receiving the annual tax settlement notice to the State Treasury and submit a copy of the tax payment receipt to the tax authority.

4) Business Income Tax

Foreign participants and foreign contractors must pay business income tax in the following cases:

- Selling oil in Vietnam not in accordance with domestic market requirements as stipulated in Article 15 of the Contract.

- Selling materials, goods, providing services, leasing assets... outside the scope of petroleum activities as defined in the contract.

In these cases, the declaration of tax payment, tax rates, etc., shall be applied in accordance with the provisions of the Law on Business Income Tax and the guiding documents currently in force.

5) Export Tax - Import Tax

Foreign contractors are exempt from import tax on materials, equipment, and goods serving petroleum activities; they are also exempt from export tax on petroleum and the aforementioned materials and equipment when re-exported out of Vietnam. However, when the reasons for granting import tax exemption for the aforementioned materials and equipment change compared to the provisions in the Contract (for example: These materials and equipment are not used for petroleum activities, are not re-exported out of Vietnam but consumed in Vietnam or disposed of in another way), the contractors have the obligation to make up for the import tax.

Procedures for making up for import tax are carried out in accordance with current laws.

6) Tax on Subcontractors

Subcontractors participating in production and business activities within the scope of the Contract shall be subject to tax payment according to the current laws on taxation for subcontractors in the oil and gas sector.

However, foreign subcontractors operating outside the forms of foreign investment stipulated in the Law on Foreign Investment in Vietnam shall not be required to pay subcontractor tax for contracts where the work is performed outside Vietnam.

The Ministry of Finance authorizes the Vietnam Oil and Gas Corporation to collect tax from the aforementioned foreign subcontractors.

The Vietnam Oil and Gas Corporation shall have the responsibility, authority, and enjoy all benefits while organizing the collection of tax from foreign subcontractors as currently prescribed for subcontractor tax.

7) Personal Income Tax

Vietnamese employees and foreign employees working in Vietnam for foreign contractors and foreign participants shall be liable to pay personal income tax according to the current laws on personal income tax. For foreign employees working in Vietnam, non-salary income received in non-monetary forms (such as housing expenses, medical services, and similar items) shall be excluded from taxable income. Foreign contractors and foreign participants shall be responsible for submitting to the tax authorities their policies regarding their employees to serve as the basis for determining taxable income.

III. CURRENCY FOR TAX PAYMENT AND TAX COLLECTION RECORDING

ACCORDING TO THE BUDGET CLASSIFICATION

1) Currency for tax payment

The currency unit used for declaration and payment of various types of taxes as prescribed in this Circular is the United States Dollar (USD).

2) Tax Collection Recording

Revenue collected for the State Budget under this Circular shall be recorded in Chapter 16, Type 01, Clause 02, Item 2 of the current Budget Classification and the corresponding revenue items as follows:

- Export Tax: Item 04

- Import Tax: Item 05

- Profit Tax: Item 19

- Resource Tax: Item 20

- Personal Income Tax: Item 25

- Other Tax Revenue: Item 30

IV. COMPLAINTS AND VIOLATION HANDLING

1) Right to Complaint

Taxpayers have the right to file complaints if they disagree with the tax handling decisions made by the tax authorities.

The complaint must be submitted to the tax authority that issued the tax handling decision within thirty days from the date of receipt of such decisions. While awaiting resolution, taxpayers are obligated to fully comply with the tax handling decisions of the tax authority.

If taxpayers disagree with the tax authority's handling decisions on complaints or if the tax authority responsible for handling complaints does not issue handling decisions within thirty days from the date of submission of the complaint, taxpayers may appeal to a higher-level tax authority. The time limit for taxpayers to submit appeals to a higher-level tax authority shall not exceed thirty days from the date of occurrence of the right to complain.

2) Responsibilities of the Tax Authority in Handling Complaints

All levels of tax authorities must examine and resolve complaints within fifteen days from the date of receipt of the complaint. For complex cases requiring investigation and examination over a longer period, the tax authority must notify the taxpayer; however, the deadline for resolving complaints shall not exceed thirty days from the date of receipt of the complaint.

Decisions on handling complaints must be implemented within fifteen days from the date of issuance of the handling decision.

3) Violation Handling

Any violation of the provisions of this Circular shall be handled according to the current laws of the Socialist Republic of Vietnam.

3.1 Taxpayers who fail to comply with regulations on tax registration procedures, tax declarations, accounting bookkeeping, use, and retention of vouchers shall be warned or fined depending on the severity of the offense.

3.2 Taxpayers are responsible for the truthfulness and accuracy of the tax declarations submitted within ten years. During this period, at any point if the tax authority discovers fraudulent declarations or tax evasion, in addition to paying the full amount of tax as prescribed by law, they will also be fined one to three times the amount of evaded tax.

3.3 Taxpayers who delay payment of taxes or fines as stated in the tax notice, tax collection order, or other tax authority decisions shall, in addition to paying the full amount of tax or fine as prescribed by law, be subject to a daily penalty of 0.2% (two thousandths) of the delayed payment amount.

V. IMPLEMENTATION

1) The Ministry of Finance assigns the General Department of Taxation to direct the Baria-Vung Tau Provincial Tax Office to organize tax collection activities for taxpayers as prescribed in this Circular.

2) The Baria-Vung Tau Provincial Tax Office shall be responsible for:

- Organizing tax registration for taxpayers according to current regulations.

- Cooperating with representatives of the Vietnam Oil and Gas Corporation in the Contract (currently the Exploration and Production Company) to organize tax settlement work simultaneously with cost recovery auditing.

- Reporting the tax obligations of each taxpayer to the General Department of Taxation immediately upon receipt of the tax declaration and a copy of the payment receipt.

3) Taxpayers are obligated to register for tax, submit tax declarations, and copies of payment receipts in accordance with the deadlines set out in this Circular. They are also responsible for providing complete and timely documentation and information as required by the tax authority.

In the case of the BHPP company acting as the representative of foreign contractors in the Contract, in addition to fulfilling the tax declaration and payment obligations as prescribed in this Circular, it must also provide the tax authority with the following declarations:

- Quarterly production declaration;

- Quarterly and annual cost and deductible expense declaration (if applicable);

- Cost recovery declaration;

- Oil profit and gas profit declaration;

- Product pricing declaration (this declaration is the obligation of the ZARUBEZHNEFT contractor to submit to the tax authority);

The content and timing of submission of the above declarations shall comply with the Contract's provisions on the submission of contractor declarations to Petro Vietnam.

4) This Circular shall take effect from the date of signature. However, the provisions concerning the tax obligations of taxpayers shall take effect from the date the Product Sharing Contract becomes effective. During implementation, any difficulties or obstacles should be promptly reported to the Ministry of Finance (General Department of Taxation) for further guidance and supplementation.