On October 10th, the State Council issued the Decision of the State Council on Amending the Provisional Regulations of the People's Republic of China on Resource Tax, which revised the regulations on resource tax collection. Comment:

1. The failure to modify the coal resource tax to an ad valorem taxation method is beneficial for the coal industry, but it has already been anticipated by the market. The ad valorem taxation of resource tax is a major measure in China's tax system reform. However, the revision of this regulation, although adding an ad valorem taxation method, currently only applies ad valorem taxation to crude oil and natural gas, and gradually expands to other resource products when conditions are ripe. The coal industry had negative expectations of resource tax based on price for many years. The release of this revision decision ultimately clarified that coal is not currently included in the scope of price based taxation. However, this positive trend has already been anticipated by the market and is expected to have limited impact on stock prices;

2. The resource tax standard for coking coal has been adjusted, but it is expected to have little impact on the profitability of coking coal enterprises. According to the recently released "Table of Resource Tax Items and Rates", the tax standards for coal resources are divided into coking coal and other coal. Among them, the tax standard for coking coal is 8-20 yuan per ton, and for other coal, it is 0.3-5 yuan per ton; Compared with previous regulations and adjustment provisions on resource tax (mainly the Provisional Regulations on Resource Tax of the People's Republic of China issued by the State Council on December 25, 1993, No. 139, and the Notice on Adjusting the Applicable Tax Standards for Coking Coal Resource Tax issued by the Ministry of Finance and the State Administration of Taxation in February 2007), it can be seen that for coking coal, the original tax standard was 8 yuan per ton, but this time there has been an increase of up to 20 yuan per ton. This is mainly because coking coal is a scarce resource in coal resources, and different tax standards are implemented for coking coal and other coal resources, which is conducive to the regulatory function of taxation and promotes the rational development, utilization, and protection of coking coal resources; Due to the high price of coking coal, even if it is levied at a maximum of 20 yuan per ton, the impact on coking coal enterprises is minimal. Taking Xishan Coal and Electricity as an example, the current price of coking clean coal (including tax on the vehicle plate) is 1500 yuan/ton, excluding value-added tax at 1282 yuan/ton. The proportion of 20 yuan/ton in resource tax is only 1.56%, and the increase from 8 yuan/ton to 20 yuan/ton is only 12 yuan/ton, accounting for 0.94%. In addition, it is necessary to consider uncertain factors such as whether the tax department will actually levy according to the highest limit. In addition, the negotiation ability of coking coal enterprises is relatively strong, and it is easy to transfer. Overall, the adjustment of coking coal resource tax standards has little impact.

3. For "other coal", the tax standard has not changed this time. This is slightly better than the previously rumored expectation in the market that it may be adjusted to 0.3-8 yuan per ton. For other coal types except coking coal, it has a slightly more neutral impact.