Disclaimer for consultations and explanations

-I-

Explanations, overviews and consultations in matters of application and interpretation of issues of the tax law of Russia (hereafter referred to as Explanations) provided by specialists to a particular customer, or an undetermined range of persons (including those compiled by specialists of the Center of Accounting and Tax Law "Consultant" on customers' request), may only be used to inform the persons receiving such Explanations about one of the existing points of view on the matter brought up in the customers' query.

The person receiving the Explanation remains under no obligation to apply it.
Explanations bear no legal value or consequences, both for the receiving party and the issuer of the Explanation.

Persons receiving the Explanations may apply them at their own risk.

\|	Neither Center of Accounting and Tax Law "Consultant", Audit Firm "Consultant", nor their staff not shall bear any liability for the consequences of the application of Explanations.

-II-

A similar position to that stated in item 1 has been assumed by the Ministry of Finance of Russia in relation to the majority of its explanations in Letter dated August 7, 2007 N 03-02-07/2-138

In particular the Letter states:

"Subjects of tax legal relations must consider the published written explanations provided by the Ministry of Finance of Russia alongside with other publications by specialists in this domain".

-III-

Concerning decision-making on actions based on:

Explanations or consultations of specialists;
Explanations contained in Letters of the Ministry of Finance of Russia and FTS of Russia (and references to such letters in Explanations of specialists);
Existing judicial practice (and references to such practice in Explanations of specialists);

one should consider that not only Explanations of specialists and explanations provided in Letters of the Ministry of Finance of Russia and FTS of Russia may contradict the judicial practice, but also the existing favorable practice may change radically, in particular:

Any judicial certificate may be reconsidered based on newly discovered circumstances (within 3 months allocated for a review application), if the Supreme Arbitration Court of the RF has changed the practice of law application after such judicial certificate has been issued. Practice may be changed on the basis of Resolutions of the Plenum of Supreme Arbitration court of the RF or Resolutions of the Presidium of Supreme Arbitration court of RF, including those made on the results of hearing of another specific case by means of review procedure.

This procedure is explained in the Resolution of the Plenum of the Supreme Arbitration Court of the RF No.14 dated 14.02.2008.