Previously, the factors which the Government Commission took into account when deciding whether to approve a transaction requiring counter-sanctions clearance could include an undertaking (if the Government Commission thought fit to impose one in its discretion) to voluntarily pay 10% of the purchase price to the state budget. Obviously, if the price was minimal, next to nothing was to be paid.
Now, the contribution, if imposed, will be calculated with reference to the fair market value of the asset to be sold, rather than its (contractually agreed) purchase price.
Read in detail in the alert at the link:
https://stonebridgelegal.ru/media/files/Alert_Counter_Sanctions_Regulations_ENG.pdf
