However, reducing the tax bill from 7 billion rubles ($246.74 million) to 3 billion rubles ($105.75 million) might also be part of the authorities' campaign to prepare Samaraneftegaz for a sale to state-owned Rosneft, since the ruling is unlikely to ease pressure on the embattled oil giant. Yukos still owes the government around 450 billion rubles ($15.86 billion) in back taxes, including bills not yet rubber-stamped in court. At the same time, relieving Samaraneftegaz of part of its liabilities will clearly play into the hands of its future buyer if the government decides to sell the asset to cover Yukos's hefty tax bill.
Analysts name state-owned Rosneft as a top possible bidder. Rosneft has already taken control of Yukos's former main production asset Yuganskneftegaz, which produces 50 million tons of crude per year and has its own tax bill of nearly $5 billion. Rosneft was quick to sue Yukos for Yuganskneftegaz's back taxes, accusing the parent company of involving its subsidiary into illicit tax optimization schemes.
If the arbiters rule in favor of Rosneft, it is likely to take Samaraneftegaz after already having won $2 billion from Yukos in Yuganskneftegaz's lost profits. Rosneft will then have enough receivables from Yukos to take over Samaraneftegaz, from which it has already arrested shares.