Note to Kr 0 1 Salt
FWM: 9 Stherington
DATE: 28 My 1991
REF: Xs Ise
cc: Kr N F Droughtoo
Mr R X Pilbeem
Mr D V Surdeou
a & D rmim
Thenk you for your letter of 17 key 1991.
The turnover figure of L1529m is wrived at by starting with the
company plan figure of L1768m. which mccludes the Mm inter-Troup
mass.
If we excluded the cigar group and leaf processing companies from
IkAno we would than have to do the *mme for DU. Their leaf exports
alone am $122a to when domestic lea sales and cigars am added I
suspect that the AA7Co allocation would cam out worse. David
Surdmau confirm that the E1624a for SW represents total external
sales of tobacco products.
I still think that external not turnover should be used as a best&
for all fit allocations. We cm live with this ovem a long period
of time and It should be ... I table to tax authorities. I do met
thish, that the lower of profits unde by RAT long long an sales
through to China should affect this principle nor should the
lateral arreng - a for the M7Co allocation.
I believe that the approach to Xmmsoo should case from Martin
Broughton. As the German Revenue authorities will mat allow a profit
uplift them in me point In raising this particular matter with than.
You will appreciate that I ma not able to agree =7 allocation
formula. What I an trying to do is to work out a formula which I
holism would be acceptable from both the point of view of the
members and the various Arvenue authorities. Omm I be" yaw
agrowboat and be" written to 1W again, I will be in a position to
make recimmendations to the TSW.
'7
XS: ar: corres/salrdf
TIQ
CD
COPY PRODUCED PURSUANT To VILD. OF
B.A.T INDUSTRIES p.Lc. MINNESOTA DEPOSITORY
CONSENT JUDOMENT DATED SW98 04 STATE OF A#mWSOTA, ET AL V. PHLV A#ORFW Er AL- CASE NO. CI-944M