The amendment does not introduce a new tax; rather, it revises the calculation method of the existing special tax. The new rules will apply for the first time to tax liabilities relating to August 2026.
The tax is linked to the price difference between Brent and Urals crude oil. Brent serves as the international benchmark crude oil, while Urals crude has traditionally been available at a lower price. Where a refinery processes lower-priced crude oil while selling its refined products at prices aligned with international market levels, the resulting price differential may generate additional profit. The purpose of the special tax is to capture a portion of this additional income arising from market conditions.
Under the previous rules, no special tax was payable on the first USD 5 of the price difference between Brent and Urals crude oil. The 95% special tax rate applied only to the portion of the price difference exceeding USD 5. Consequently, where the price differential did not exceed USD 5 per barrel, no special tax liability arose. The adopted amendment changes this approach. Going forward, the portion of the price difference between USD 2 and USD 5 will be subject to a 50% special tax, while the portion exceeding USD 5 will continue to be taxed at 95%. As a result, special tax liability may arise even where the price differential is relatively modest, as the previously untaxed USD 2–5 range will now also fall within the scope of taxation.
The amendment therefore does not alter the scope of taxpayers and does not introduce a new tax. Instead, it modifies the calculation mechanism of the existing special tax. At the same time, the structure of the tax changes from a single-rate system to a two-tier regime, providing a more differentiated approach to the taxation of additional income generated by the Brent–Urals price differential. The adopted legislation also extends the application of the special tax to the 2027 tax year, while the revised calculation rules will first apply to tax liabilities relating to August 2026.