In a world of low commodity prices the potential for conflict between hydrocarbon producers and governments over tax revenues is exacerbated. In Russia this is even more true because the state relies so heavily on taxes from the oil and gas sectors and because producers are increasingly having to invest in new more remote assets rather than rely on declining Soviet-era low-cost fields. In the gas sector the state has attempted to address this issue by offering a differentiated royalty system that allows discounted rates for new investment, but because of the oversupply of gas in Russia this has led to some unforeseen consequences. Gazprom, as the largest producer, has prioritised production from new more expensive fields with a lower tax burden rather than exploit some of its lower cost existing assets, with the result that government revenues have not been maximised and Russia’s competitive position in global market has not been optimised. This paper explores the implications of this outcome and discusses potential changes in policy which could alleviate the problems. The paper is available for download on the Oxford Institute for Energy Studies website.