DRAFT 1994 KEY AREA PAPERS 14 th March 1994 Ui r" ON r,; -0 CO 01 \ BATCo document for Province of British Columbia 23 April 1999 ~Z~ 7 Ila i:W 77 4 ..3fN- CD c= ILA; ,-:1 -3 a BATCo document for Province of British Columbia 23 April 1999 EMMLAZ4 RRSOURCES NUMON BATCOS HVMAH RESOMM FUNCrION WUL ADD VALULTO THF- B. BY CREATING THEENVIRONMENI-TO'. ENSURE THAT TEM B~EgTr' AVAILABLE IT -DEVELOPED TO MAMM-MML-r' CONTRMIMON TO THEACHIEVEMENT OF COWANY OBJECTIVW.' Through the adoption of the 0owing key principles, BATCo's Hun= Resources Function wiU achieve its mission:- SUCCESSION PLAINNIING We wil.1 have the right number of employees with the appropriate skills in the right place at the risk time. RECRUITINMNT & SELECTION At every level of the organisatioa, we will recruit and select those people with the highest potential to advance our business. REWARD Our reward philosophy wiH enAle us to recruit and retain the best avail~lc Went, and will engender the highest level of perfortrance =xmgst our employees. TRAINING AND DEVELOPMENT Managerial and technical excelleoce will be developed intc=Uy using training methods that wiU support the business and encourage personal growth in order to develop woridclass talent fiam within. STRUC`rURE Organisational structures will have the appropriate number of levels with clear individual and tearn accmintabilitics in order to provide the opportunity for cross-Ruxtional and individual development. EMPLOYEE RELATIONS To cre= the cultural enviroanza which will ensure cmplmees at all levels are conumued to thew objectives, to the means of achieving those objectives, and to the Company. PRODUL-nVITY To optimise work output compatible with the cornpany's objectives. L11 C:) t"i C711 co 00 BATCo document for Province of BritiSh Columbia 23 April 1999 SUCCEMON PLANMNG ~ BATCo will iniplancat a worldwide grad= traince scheme with consistent training and career paths in order to enstire that in the fi=m apart ftorn selec:vve recruitznect~ we grim our senior mamigeri%ent popul=on from wW= ~ All Operating companies will use the 14- Pxsmr= Phnning (KR-P.) syst= iaili6n the standard definitions; of: * Key Positions: positions critical to the achievement of Company objectives # Deyelopment Positions : pcsi&w providing ideal development opporainicies for Fligh Potential staff * High Potential Staff: employees wiEh pc=tial to rLw to at least Depa=e=.Maca&= level # Potential Staff: employees with potectial to progress but who do tax mect High Potential criteria * Obstacles : employees without further poteritial to progress who am blocLing Key or Development positions ~ Where there am changes to the HRP dambase these: will be advised to the C== ca a monthly basis. ~ T'he HRP system will be used to mcnitor compliance with BATCo's Key Pn=plm cf Succession ftnrling. ~ An Operating units win systemancally W=mfy kugh potential stLff throggb the use of dw- PACE appraisal pro=ss, Career Driclopmcas Conzinitzees and, where possible, the Use of Develop- Ccz= techniques. RECRUITMENT Bcfbre d=ding whetim to r== to a position the HR function will -- with Ii= the need and appropriat of internal candidates. All HR departzrients must have at least am professionally trained in-- Mie ultimate, selectinn rests with I= management therefore they must be provided with the appropriate skills of intervicwin& In all cam of nunaglInellt rwruimi= die ML"Yant Functional Director should finally approve the appointmenL All jobs will have a role profilm For the recruitzrient of nunagers into key positions HR dqwm=tx either frurn ~Ic C=nc, or from within the Region must obtain the = of obje~ selection techniques- U-I C:) r\J ON c0 1 ~0 BATCo document for Province of BritiSh Columbia 23 April 1999 REWARD The Centre will have a conststent internwaonal staffaad reward Mectlanism. ALI Operating units will adopt BATCo!s vcrs= of the Wt=auooal management grade structurt trough the consisteztt applicancm of the Hay method ofjob evaluaboa. All Operating units will have in place a Board Compensation Committee to: # Ensure that remuneration policy at all times c==wtcz a competuve advantage in temu of a-acting and retaining top quaLity managern- * Promote a good woricing imowledge of local market practice. # Cnamily challenge and analyse the reward padcage mm # Easure that padmges am performance orimted. TRAIMING AND DEVELOPMENT ~ Every manager will have a development plaa. ~ Tbe prime vehicle for ideaffying training needs will be the ?ACE' appraisal system. ~ A key feature of & line manager's performance review wiU be to assess the effectiveness of subordinate re"ics. ~ Comprehensive trammg records will be kept for each manager. ~ Development will be principally on the job and is a am management responsibility which wrill include- # Self Education & L=ming # TeamWorking # Task Forces * Projects # Secoadmects/Assignmew # External Representmion # Internal/External Courscs An Operating Companies will adopt BATCo's consistent three level ftmework for Training and Development in order to grow woridelass talent fiorn withim Development will mlso fbcus on the acquisition Oftechnical ==Be= within the fiInctic"L rQ (71 BATCo document for Province of British Columbia 23 April 1999 STRUCTURE ~ At least a=ually Operating ututs will critically review dmr orgatusation, to achieve: * Flatter Structures # The appropriate level ofdocision making * CbaLkn&gjobco-fbrst&ff ~ Opportunities must be created to utilisc rnultifiLrictional task fbrces and project, groups. will enable key individuals to gain exposure to other fitactions and discipUnes. EN2LOYEE RELATrONS & PRODUMVITY Operamig units will develop effkarve intemal moo-way conmtnunicanon and Lnvolvcnv= mechanisrns (distinct from Trades Unions or Staff Association channels) wi~ich eacourage =nployees to identify timnselves with the Company. Under the di~vcticn of the BCC, Operating units will agree payAx=fit reviews for all ernployce groups, including dw principle of productivity growth shared with shaM%oWe:%, customers and fimher business development Operating units will have well dtfined policies on such rnatters as redundancy. equal opportunity, eariy/voluotary rcdrcmem dismissal and grievance procedures. Operating units %&-ill constantly review organEsation structures, amning and out-sourcmg oppomuuties in order to achieve gre= people productivity (i.e. low= cost provider sum and rnir~ overheads). Operating =ts will operate the high BAT Co fkalth and Safety standuds, including etoployea invOIVW=L C-- rl: C7 \ BATCo document for Province of British Columbia 23 April 1999 BATCo document for Province of British Columbia 23 April 1999 UTTLISATION OF PRODUC'110N RPqOURCFZ 1. C-Macirv Plan Manufacturing capacity will be planned to exceed Marketing fbL by 10% except where markets are volatile~ when a higher provision may be required. Where possible, contract manufacture, which absorbs surplus capacity in other BAT companies, must be considered as an alternative to investment in new capacity or where there are overall cost benefits. For hygiene reasons, Primary manufacture should not be planned forfull three shift operation. Contingency plans should be made to respond to a disaster at a producdon site or warehouse or at a key supplier. Plans should be consistent with the form, being developed at Southampton plant and should include procedures to-- Assess then minimise risk Manage the disaster and minimise its affect on personnel and propeny Establish alternative production sources in the event the disaster could produce interruptions to market supply Restore production capability. 2. Machinerv Investment in new machinery must always maintain or improve product quality. New technology will be adopted where product and commercial betiefit can be shown. Machinery purchases should be consistent with BATCo and regional machinery standardisadoo. Machinery utilisasion should be maximised, including the use of multi shift working where this is cost effective. Production Costs Companies should aim to be the lowest mu producer where competitive markets exist and to aefiieve, cost reductions of at least 5% per year in real per millemsts (excluding depreciation) on average over the plan period. Competitor production performance mid capability should be specifically reviewed on a regular basis with particular reference to their production strategy and production cost structUte. V1 CD CD 13 ATCO document for Province of Brifth Columbia 23 April 1999 Production plans to reduce costs should identify:- 3.1 Targets fbr improving productivity in the direct and indirect areas. Strategies should include. Flexible Working practices Team Working and *Mini Factories* Reduced Product handling Contracting out services, if financially viable, and with a view to improving the quality of service Use of aftetive information systems .Machinery investment where justified Reduced layers of management 3.2 Targets :br process and material cost reductions. Strategies should include:- The principles of MRPII Raduc::iocs in stock levels, including Finished GoodsWMS and R&RS Rxionalisation of specifications Reductions in energy usage ratios and energy costs Ratonal Cooperation on stock items Use of Procurement Dept. to ensure Competitive Purchasing 3.3 Targets fbr improved use of existing resources. Sa=e_-'es should include:- Machine Efficiency improvement programmes traprovemems to material and cut tobacco quality Comprebensive maintenance and machine cleaning programmes On floor m-n- ement and supervision Improvements in skills, through local or regional training Reduced machine change over times Disposal of surplus assets. 4. Product O-iirv Companies should plan that product quality meets the expectations of the consumer. is superior to that of competition where this exists and that~ as a minimum, products meet standards set under relevant legislations. VI C:) Ili C711 r,.) rIJ CZ) CD NJ BATCo document for Province of BritiSh Columbia 23 April 1999 Production plans to improve product quality should show targets for improvements in Product Quality Ratings, performance against competition (where appropriate) and reductions in consumer complaints. Strategies should include:- Moving responsibility for quality to machine operator level Quality training at all levels Quality Performance Audits and Reviews at shop floor level Compliance with QC Protocols and Q Methods Investment in on line quality measurement Off line quality measurement at the point of manufacture Quality data and complaints analysis Quality systems and procedures which are consistent with the principles of IS09000 .Machinery investment where specifically justified Effective Machine programmes Working with material suppliers to enhance the quality of their produ= aad services. 5. Health ;,,id Safetv Companies should aim to eliminate all accidents and risks to health w personnel on BAT premises. Production plans to improve Health and Safety should show strategies ibr reducing the number of accidents and the time lost through accidents and for improvemems in hy iene. Strategies should include:- Compliance with BAT safety requirements as expressed in BAT Safety Manuals and Guidelines Ensuring that contractors are carefully selected and supervised and are obliged to adhere to BAT standards of saferv Compliance by visitors with BAT safety standards General and job specific safety training fbr all employees An effective safety organisa on and regular safety meetings and audits at Company and Departmental level Promotion of the safety message through specific campaigns and pmgr=mes such as "Safety Week* Provision of We systems of work Detailed investig2don of all accidents and incidents which could have led to an a=ide6t Machinery which is fully guarded and interlocked Safe storage and use of hazardous substances Effective system for fim prevention and fire fighting at all locations. including remote warehouses and depots Elimination of electrical b-zards Meeting all relevant legislation Maintaining the highest standards of hygiene in the factory, lav=ries. kitchens etc.. including regular Hygiene Audits rQ 0 CD ILA BATCo document for Province of British Columbia 23 April 1999 666~ I!jdV, f:Z L-.iqtunlO:) 4SRIJF3 jo ODUIAOJd JOI lumunoop oo.LVS al C:) C\J CIA ID Ln Nc Z~. UA 1993 KrY ARrA : FNMO'.%NfFWAF ISSUFq Each company should review the potential impact of its activities on the environment. As a minimum it will comply with all applicable laws but the company should aM be pro-active. meeting best standards of practices to safeguard the environment. Aspect of the euviro-c-1 plan should include: - Improving the impact of factories on the environment including Effluent, Air and Odour Emission, Noise, Dust, CG2 releases etc. Plans to meet the BATCo Guidelines on Environmental Issues, including maximum residual limits (MRL) of permitted agricultural chemicals on tobacm products. In companies where leaf is caused to be grown, the plan should include: - Meedng self sufficiency targets in wood fuel usage. StratMv for meeting BATCo Guidelines for the use of agriculuiral chemicals. Any changes in the use of fenilisers that will impact on the environment and include any other major at= of concern e.g. Irrigation. Soil erosion. etc. Proposals to reduce packa&g material usage and for mi-ir-king. re-using or recyc!4 of solid waste. Identific3rion of emerging issues. Public Affairs department should include strategies for responding to and communication about all issues. Ln rQ CD Lr", BATCo document for Province of British Columbia 23 April 1999 BATCo document for Province of British Columbia 23 April 1999 Ln CD (31% rl%.) rIj C) CD a, 3 ~ ,n 666~ jjjdV CZ eiqtunloC) 4SIIIJ8 10 63UIAO-'d JOJ JUOLun3op oo.LV8 x 771~ . . ........ zo 3:1 C V-z A.- L.- N 1993 KEY AREA PAPER: PURCHAS WG I PROCURrNMENT The result of close co-operation between BATCo and the other Industries companies during 1993 his been to neptiate global supply agreements with key supliers for FUter Tow, Cigarette Paper, Plugwrap and printer's SBS Board. The details of the impact on individual BATCo companies should now have been communicated, together with an irriplementation programme to achieve the service and cost benefits identified. This has effectively rationafised our supplier base for these key materials to those who can meet and sustain the quality, service and cost requirements ofBAT as a whole. It is therefore the continuing deve!opmenE of our material strategies that rpresents [he thrust of BATCo Procurement's activities for the plan period. This will specifically focus on Duplex Board, Paper, Tipping . I _- Film and Inner Bundling. In order to ensure that we m1tieve the benefits identified, it Is vital that Operating Companies do not deviate from the sourcing and pricing agreements made on behalf of the Group for Filter Tow, Cigarette Puer, Plugwrap and printer's SBS Board without reference to BATCo P-ocurement. Furthermore. as sourcing strategies r-or the other materials identified are developed, any planned changes in sourcing or pricing policy for such additional materials will need to be likewise advised. The following have been identified as Purchasinw?rocurement Primary Objectives: 1. To ensure that, within the bounds of commercial viability the hi0est available levels of quality and consistency of materials are used an our key brands, particularly Intemadonal Brands. 2. To reduce BATCo's materials spend in real terms throughout the pian period by taking advantage of BATCo's and BAT Industries' annual material purchasing volumes. 3. To ensure that materials used minimise total cost - taking into acccunt all costs incurred ie purchase price. overhead costs. delivery, packing, storage. finance, machine performance and x-tual material wastage. 4. To review purchasing of items other than wrapping materials that may offer Group-wide benefit ifvolumes or nestotiations are co-ordinated. 5. To ensure that materials used meet all established criteria and gruidefines laid down by the Additives and Materials Guidance panel regarding Health and Safety of our workforce, our neighbours and our customers and that theis manufacture, packing, use or disposal is in line with BATs Emironmental policies and guidelines. Specific strategies to achieve the above include: a) In conjunction with the IBG. to develop, implement and monitor comprehensive Lr' Packaging Material Standards fbr each brand. C-- NJ (71, N; r"i C) BATCo document for Province of British Columbia 23 April 1999 b) To rationalise material specifications used throughout the Group without detriment to product quality or design flexibility and to document agreed specifications My. c) To rationalise BATs suppliers for key materials worldwide in order to focus our purchasing power with quality suppliers who are able to support our long-term growth and development. d) To use selected suppliers where practicable to be the sole source of particular materials to individual manufacturing locations e.g. single sourcing of tow to any one company to Improve logistics and stockholding. e) To verify. where appropriate, with the Additive and Materials Guidance Panel (AMG? - based at BATCo Technology Centre. Southampton) and Group Environmental management~ all materials that are used. To agree and implement a Group-wide supplier rating system. To support the ongoing development of the strategies noted above, BATCo has now F completed detailea materiai surveys for all Operating Companies, and is identifying the issues, suppliers and strategies for each region which are an integral part of the global strategies being developed with the other BAT Industries tobacco companies. In parallel with &s, the rarionalisation projects in 1994 are being extended to include plugwrap, tipping, film and inner bundling. It is intended to continue with the prograrrune of Regional Purchasing Conferences to develop and communicate the issues of sourcing, quality, service, cost and ralionalisation with each of the regions. together with the ongoing exchange and update of purchase data. -kcr zordinaly, It IS recommended that: P2 ckaging Quality standards for International Brands should be verified to ensure conformance to international brand standards. Areas of doubt should be raised with [BUS or this department. Standards for local brands should be developed to mirror those of Interriational Brand manuals. Rationalisation opportunities between brands should be sought to minimise stock items and cost eg Tear tapes, Tippings etc. All locally sourced materials in contact with our product should be confirmed as approved by AMGP and other materials m= conform to local food and health legislation or, if not available or suitable, to US Food and Drug legislation. I N o new specifications or supplier3 should be introduced for key materials sourced from international manufacturers without first discussing the proposal with this department. Current local suppliers of materials should be assessed by Operating Companies in terms of quality, service and cost. Local rankings should be Lrl developed to identify orders of preference. Alternative suppliers should be C__ identified and investigated to determine suitability. Local material supplies rll.~ should be reviewed to identify differences in quality, service or cost with current international standards. NJ Ln BATCo document for Province of BritiSh Columbia 23 April 1999 Supplier reiadonships - BATCo must aim for the highest possible business ethics and professionalism in all our dealings with suppliers. We should not allow suppliers to influetwe us through inappropriate gifts or entertainment. We should insist on absolute integrity and honesty from ourselves and the suppfier regarding infbrmaxion about each other. We should never divulge their pricing to their competimrs. Where possible we should aim to establish long-term relationships with our supply base that allow continuity and awareness of each others needs and iature requirements. Historically. suppliers have taken the approach to organisations like ourselves of 'dNide and conquer'. We must ensure that communciation within our Group is suf5ciently 3ood to prevent this occurring and suppliers must be made aware of this and your adherence to defined corporate sourcing strategies. Local suppliers must not be allowed to hide behind barriers and tarrifs which preclude competitive imports. They must be encouraged at eve.-y opporturuty to compare Lhemseives with current international standards. Conversely, local suppfiers who are competitive in quality, service and price may be of significant Lnterest to other Group members and should be encouraged to contact this office after discussion. March 1994 C:) BATCo document for Province of BritiSh Columbia 23 April 1999 666~ IIAV VZ eiqLunlo3 4S.141,113 10 OOUIAOid -joj JuaLunoop oo.LVE3 CC) C:> I cli "o C-4 C) LO vW, 59 M . - --7-7 m A-17 ",;:~ -,AA3- . . . . . . . . . . -2, W'F; "'C SECRET ~B A T) INDIRECT TAXATION OF TOBACCO PRODUCTS KEY ARF--k PAPER CD r1 j (71 NJ r') C:) BATCo document for Province of British Columbia 23 April 1999 CONTENTS KEY AREA: INDIRECT TAXATION OF TOBACCO PRODUCTS A. THE ISSUE B. POLICY C. STRATEGIES D. EXPLANATIONS OF STRATEGIES Levelof taxation Frequency of Tax increases Structure of Taxation Excise collection Repional Taxes Retail Prices Retail Price Index Company Responsibility Government Relations International Trade issues Industry Relations CompetitorMonitoring Value Added Tax Appendix I Structure of Taxation Appendix II Excise Administration C-- r,; C7, BATCo document for Province of British Columbia 23 April 1999 S'FCRVr KFY ARFA : INDTRFCT TAXATION OF TOBACCO PRODUCTS A. THE ISSUE Tobacco indirect taxation (excise tax, Wes tax, VAT and import tariffs) is the most significant element of the retail selling price of tobacco products and hence plays a major role in determining the commercial environmen'E in which we operate. In particular, indirect taxation determines the level of retail prices. the price structure and Lherefore the overall pattern of smoker deniand for our products. It is also closely linked to. and significantly influences the level of profitability and cash flow perfor7nance or an operating company. E--,cise taxation and VAT has always been a key issue but is becoming even more so because of Gove-nment inc== in the level either for revenue or health reasons, with resultant higher real prices. Also, competition, particularly P.M. increasingly seek to influence the structure of the taxation system in order to optimise their competitor position in the market place. The critical product cam-gory is cigarettes, which accounts for well over 90% of global tobacco consumption, this paper therefore focuses upon cigarettes, although there is some rere-rence. to other tobacco products. International co-operation and cross frertilisation between Governments is increasing with regard to indirect taxation, as a result of which both taxation levels and structures are being shaped by external influences. Tobacco indirect taxation is therefore an issue for General Management although its most direct impact is in the functions of Marketing and Finance. General Managers should advise Nlillbank of all changes in tax structures and levels, and discuss any proposals for change with tMillbank prior to their submission to Government. B. POLICY To manage the cigarette indirect taxation issue in order to establish the most appropriate retail price structure whilsE optimising profitability and cash flow over the long term. In most instances. long rem profit optimisation will normally result from a totally or predominantly specific excise taxation structure, in preference to an ad valorem one. The optimum balance between specific and ad valorem will depend upon the brand mix of each company. Cr. C-- r1 _' CT% NJ C-~ r1 J U4 BATCo document for Province of British Columbia 23 April 1999 C. STRATEGEES This policy will be achieved by focusing upon the following main strategies Seek to reduce the r= and/or incidence of excise taxation, or to ensure that its level does not increase at a rate greater than inflation. 2. To secure smaller and more frequent increases in prefierence Lo Larger and only occasional increases in excise taxation. 3. To establish a structure or system of excise taxation which results in a range of retail prices most appropriate to the BAT brand mix whilst also optimising profitability over the longer term. 4. To establish a method of colleczing the excise which maximises any excise credit terms but at least ensures revenue neutrality between when payment is received from customers and when pavment is made to the Government. maximises the involvement of the manufacturer in the collection of excise and minimises the involvement of the distributive and retail trades. The reason for this is to retain manufacturer control over the determination of the retail price which is essential for long term pront optimisation. establishes 2L single retail price for a brand either by means of a fixed retail price or a retail price agreed with the Government as the basis for calculating any ad valorem excise. makes it difficult for Govemments to impose 'health' surcharges in the future or to impose differential taxation linked to tar : nic delivery levels-, minimises the ability of competitors to underpay their excise tax and so derive a competitor advantage. 5. To manage the possible conflicts and to gain advantage from situations where indirect taxes are levied on a national and regional basis. 6. To secure maximum freedom to determine selling prices without Government intervention or approval. whilst also minimising the ability of the retail trade to vary prices from those recommended by, or fixed by the manufacturer. 2 CTN NJ NJ CD N Zb BATCo document for Province of BritiSh Columbia 23 April 1999 7. To oppose the removal of tobacco products from the retail price index, which has become an objective for the and-tobacco lobby in order to enable Governments to increase taxes and thenfore prices without considering the inflationary impact of their actions. a. To define the management responsibility for tobacco indirect taxation within your company both from the public affairs and commercial Viewpoints. 9. To maintain a dialogue and close working relationship with key Government officials and Ministers in order to influence their indirect taxation policy and to establish links with other businesses such as -alcohol, oil etc who may assist in this process. 10. To maintain working relationships with local representatives of INIF:'World Bank/GATT agencies to be aware of and influence policy. 11. To lead. but ac-, with the rest of the tobacco industry and to maximise the berefits from including other interested parties such as farmers, proc--ssors, suppliers and the trade. 121. To monitor competitor excise payment disciplines to ensure that we are not disadvantaged from either slower payment or non-payment by our competitors. 13. To seek to ensure that the application of Value Added Tax to tobacco products does not increase the total tax burden. These samegies are explained in greater detail in the subsequent sections. D. F_XPLANATION OF STRATEGTES 1. Level of Taxation 7 he combined forces of Government revenue needs and the anti- .smoking lobby have resulted in increased real levels of taxation in many countries. a situation which is likely to intensify further in the foresetabic future. Every opportunity to reduce the level of taxation should be pursued even though the achievement of reductions may never be easy. If the taxable base can be expanded e.g. by including smoking products not presently taxed, then Governments may be persuaded to effect rate reductions on cigarettes. Reductions have been achieved in the Netherlands and other countries in recent years. CD N~ CII 3 C:) r'J U11 BATCo document for Province of British Columbia 23 April 1999 Should reductions prove to be unachievable companies should contain the increase in taxation to a level below the rate of inflation or at worst in line with it. Arpments supporting this include : the inflationary and regressive impact of tax increases ahead of inflation, particularly upon lower income groups who frequently account for a disproportionately large amount of tobacco sales; the normal economic arguments that tax increases result in failing demand, employmcnt~ profitability and invesur=4 both directly upon the compan and indirectly upon suppliers; . y increzises in taxation and hence retail price can result in the emergence or growth of transit or border trade business and hence a fall in revenue vield- This has verb dramatically been illustrated recently in Canada. The high taxation policy followed by the Canadian Government, in an effort to reduce smoking incidence. has failed and the high levels of taxation have been reduced. high = increases may result in smokers dropping out of the manufactured cigarette market and switching to RYO which is often taxed at a lower level or not at all. It is conceivable that overall Governmeit receipts could fall in such circumstanc:s; increases in =ation may result in a decline in consumption sufficient to bring about a M in revenue yield to the Government. Because of the inelasticity of demand for ciga.rettes, over the longer term. this result mrely occurs. However, it is not uncommon to see a shon term decline in revenue yield which can be pointed out to Government when opposing increases: increases in taxation which reduce consumption may mean the destruction of the vitality of the tobacco industry and thus the erosion of the tax base which Government may wish to protect over the long te-m. Tlis applies even more in countries with a significant lW- export trade which depends to some extent upon the continued existence of the local industry. increases in taxation are either out of line with international or re-ional norms or would result in the incidence of taxation b;~omingr out of line with such norms. Although it can sometimes hap . . nlikely that an U-1 . pen, it is most u C-- Operating Company will be in a position, where it elects, to absorb a rs; part or all of an increase in excise taxation. C711 N) r-j C:) PQ BATCo document for Province of British Columbia 23 April 1999 2. Frequency of Tax Increases The psychology of smoker demand is such that they are more likely to a.bsorb smaller and more frequent price increases than larger and less frequent price increasets. During negotiations with Government therefore it is preferable to seek die former excise environmenE. However, this has also to be interpreted in the context of the general level of inflation in the country plus the significance of stick sales and coinage availability which may act as a constraint to the implementation of this strategy. In markets of high inflation, it is always preferable to take manufacturers prices increases ahead of inflation instead of behind it, with the exact timing sometimes determining the difference between operating profitability or a loss. The timing of manufacturer price increases however, sometimes has co be int.--grated with excise inc=ses. and it is desirable that this should be so under certain -amstarices. although flexibility not to do so should also exist. , circ 3. Structure of Excise Taxation The structure of any excise system determines the pricing scenano of the market place and has a significant impact upon the level of profitability. Both Marketing and Finance should fully understand the implications of the current excise structure and establish whether a competitor advantage might accrue from a change to a different structure. In many instances. change may be either inappropriate or impossible while in other instances change may be appropriate and possible. The structure is also highly relevant to the key issue of product quality with specific eacise normally resulting in higher product quality then ad valorem because the latter encourages price competition and hence cost and quality reduction. There is no single excise structure appropriate to BAT on a global basis because the competitor and brand mix situations vary widely. Companies should evaluate their own position in the market place in order to determine the structure most appropriate for them. A specific excise structure is more likely to result in higher long term profitability than in an ad valorem structure, however it might not be appropriate in particular situations given the current brand portfolio and competitive position. Essentially there are two broad methods of excise taxation in operation around the world which are applied by national Governments as a means of raising revenue upon tobacco products: NJI ON r1 j NJ C:) BATCo document for Province of British Columbia 23 April 1999 A smeiric system levied upon the cigarette itself by number or weight of cigarettes produced or an ad valorem system, where the = is calculated as a percentage of the retail selling or ex factory price. A oure sDecific svstern bv number of ciLnrettes levies a fixed amount of tax immpective of size, specification, cost of manufacture or retail selling price. Given that tax incidences are generally high the retail price range in the market place will therefore be limited ~ecausc any reductions of price have to be absorbed fully by manufacturers, their ability to lower prices is restricted to the vahation on costs of manufacture. In addition to having a purr specific excise applicable to ail cigarettes a 'stab or tiered' system can be applied whereby the amount of specific tax varies according to the retail price. (with lower priced ci- . a lower tax than high priced cigarettes), or other garertes attracting. -te. ( *jer c--arettes physical characterikc e.-. length of cigare Ion attracting higher tax). Some countries have a structure of cigarette taxation which is based upon a Soccific amount of wK oer k2 either of tobacco only or inclusive of the paper and filter. With such a structure the amount of taxation varies according to the cigarette specification with the result that lighter cigarettes have a significantly lower price than heavier cigarettes. The resul=t range of retail prices is therefore similar to an ad valorem structure although the tax. is a specific one. The principle effect of such a structure is that the market may switch down to either shorter cigarettes or cigarettes with lower circumferences or densities. An ad ,:;Iorem excise is a proportional tax calculated as a percentage of the retail selling price or a price agreed between the manufacturer and the Government. On occasions, it is calculated as &percentage of the ex factory selling price. With an ad valorem structure. the retail price range in the market place will tend to be quite wide because any price increase or reduction by the manufacturer will be multiplied by the ad valorem tax resWting in a retail selling price changed by an amount much greater than the original increase or reducdon by the manufacturer. ON r1 j rll~ C:) r11j Ga BATCo document for Province of British Columbia 23 April 1999 Although not strictly an excise tax, a sales tax or VAT is being introduced by many Governments as an indirect = applicable to an consumer goods including cigarettes. This is always expressed in percentage terms and is therefore an ad valorem = in addition to any end product ad valorem tax which is applied to cigarettes. If such an additional tax is applied, it is important to get Government to . t that it forms part of the overall incidence of tobacc taxitionandtat it is part of the total ad valorem element of that =. A mixed end product system is simply a combination of a sp6cific and ad valorem structure. Such a system applies in the European Union and is increasingly being adopted in other countries in order to achieve a result which is related to the needs and purchasing habits of consumers, the competitor situation and varying price segments. whilst providing a more stable tax yield for the Government- The structure of taxation for products other than cigarettes genemily ,ollows one of the above options. In the main, cigars and cigarettes do nOE directly compete against each other with the possible exception of miniarure cigars. Similarly, Pipe tobaccos. Chewing Tobac=s and Snuff do not compete directly against cigarettes. However Roll Your Own smoking tobacco is in direct competition with manufactured cigarettes. Companies must understand the relative excise incidence of these two product categories and their impact upon relative pricz levels and switching between the two categories. Although circumstances vary, the BAT policy is to minimise the price advantage of RYO and so maximise the market opportunities for manuftc-.ured cigarettes. Further aspects of the structures of excise =ation are developed in .-kppendix One. 4. Excise Collection The administration of tobacco excise =ation can frequently be complex but within this complexity, opportunities may exist to derive benefit for the Company. In all countries, the timing of excise payment is crucial bemuse of its cash flow and profit implications. The minimum objective should be to ensure revenue neutrality whereby tax is not paid until payment has be--n received from the distributive trade However, one should always press for a period of tax credit which is positive, which covers LF1. one's costs of administering and collecting the = on behalf of the Government, which covers any bad debts (if any) and which is consistent with the concept of all indirect taxation viz : that a consumption tax should be paid when the product is consumed. not C) 7 r,) 1 Z BATCo document for Province of British Columbia 23 April 1999 when it is manufactured or still in the distribution pipeline. 717here have be= occasions where Governments have increased the pexiod of tax credit instead of permitting & price increase (the latter being inflationary) as a means of improving profitability. With regard to bad debts. Governments should be lobbied to carry this risk thmnsielves, thereby limiting the risk of the manufacturers to the net cost, of Elie goods only. Experience of indirect tax systems demonscratm clearly that it is pre'L-able to minimise the involvement of the trade in the system so that the manufacturers essentially remin the optimum influence over the --utal retail selling price. In Europe in particular, the power and inruenc: of the trade has and still continues to gro re tan ., w with sul t prmsure upon manufacturers to give hi-her margins, bonuses or other inc=tive payments to the trade. One or the means whereby the influenc.- of the trade has been contained is the existence of an excise coilec::ion system whereby only the manviimr-ers are involved, and whe= the trade margin is fixed either by law or practice on the basis of --;,e price determined by the manufacturerin agreement with the Gov"..-nent. W-e-re the excise is linked to the retail price of a brand, (normally via an :d valorem element) it is necessary to have either a fixed remit pr.c.- for that brand a recommended remit selling price or an agreed price for the purposes of calculating the excise. This is advisable also bemuse it minimises the ability of the trade to reduce the remit price and so pass on to the consumer the multiplied effect of any price saving. To be able to vary the price upon which the excise is based and so vary the excise itself, would result in the trade effectively det-e-mining the retail price instead of the manufacturer doing so. In some countries BAT is at competitor disadvantage against local or national, companies who either under declare or underpay their excise liability. Although banderoles of fiscal stamps are not desirable bemuse of their negative impact Upon manufacturing efficiencies. they may offer some scope for resolving this problem. However, companies should also consider the possibility of presenting a case to Government. provided that they are sure of the evidence of underpayment. N.; all r1 _1 rQ C-- BATCo document for Province of British Columbia 23 April 1999 S. Regional Taxes In some countries, e.g. USA, Ausualia, Brazil, Canada, tobacco taxation is a =rure of Federal and Regional- This may offer opportunities to trade off one authority against another, either to achieve lower overall taxation or better tax credit payment terms. However, the mlationships between the Federal and Regional authorities recui= careful management since disharmony between the two authorities can equally lead to higher levels of taxation and worse credit terms. Retail Prices Retail prices. :a- levels and increases in taxation are often closely linked in marr; countries. Government influence varies from completely ccn:rolling retail prices to allowing full freedom to manuficrurers. Retail prices vary from being fixed by law or practice to being free. wich the manufacturers and the trade being able to change prices'I-v whatever amount they wish, whenever they wish. Because circunstance:s vary widely, it is difficult to have a global strategy. Ho%ever, the interests of the Group are best served by a situation where the company is free to determine the retail price for its brands which Should then be fixed, with the trade margin being linked to this either as a fixed amount or a percentage (a fixed amount is prererable). 'dthough it is normally difficult to dictate the degree of involvement of Government in the excise : price process, one should seek to eiiminam or minimise the involvement of the trade so that the balance of powe: stays with the manufacturers. In markets wh.---. stick sales predominate, clearly the trade plays a key role, but com=anies should examine every opportunity to maximise the prices acc.--uig to the manufacturer when excise increases are passed on to the consumer. although balancing this with the need to give the trade I satisfactory level of return based upon the actual stick price. When permitted. it is nonnally preferable for the industry to apply for and implement price increases collectively and simultaneously and to negotiate with Government. where necessary, on an industry basis. CD L14 BATCo document for Province of British Columbia 23 April 1999 7. Retag Price Index It is frequently argued by the and-smoldng lobby that the price of tobacco products should be removed from the index of retail prices of the cost of living index. This would then enable Government to impose higher levels of exc-*se for 'health' reasons, without impacting negatively upon the level of inflation. The effect of excise increases will be felt in any economy, whether or not they are included in an index of retail prices. To pre=d otherwise is naive while to exclude a bona fide product from such an index would (,ive rise -o doubts about the validity of Govmment statistics generally. Such an action would limit the use of the index in economic policy formulation and economic planning generally because the use of an :ncor:---: statistic will always have a distorting effect. Companies should oppose any such attempt, and seek to emlist the support of trade unions who urilise the index for wage negotiations, together with economists and statisticians sympathetic to the position of the industry. Although this is the general global strategy, there may be circumstances when the level of inflation combined with pric: controls may necessimm its removal if to do so is the only means of purting the industry an a basis of profitability, for example where a Government is r Mising a necessary price increase because of its effect on the index of inflation. However, this should not be underaken unless the positive results wUl accrue over the longer term. S. Company Responsibility Indirect tobacco taxation and pricing are general management issues and will always involve different business functions within operating companies. However. it is essential to have clear responsibilities for the management of the-n. The key elements are : strategic planning of exc;se am systems and pricing accounting and computation of options management of payment and administration lobbying Millbank (Tobacco Taxation Department) is building expertise and contacts and a central database of information in order to assist Ul operating companies. Based on experience from around the Group, C:) lobbying arguments art being developed in Millbank. rl.; cr, r1 i r1 i 10 C~ 1-4 r%j BATCo document for Province of British Columbia 23 April 1999 9. Govermment Relations The issue of Government relations is closely linked to that of Smoking & Health which is more fully covered in the Public Affairs key area paper, whocas this paper covers relations in the context of the technical aspects of indirect tobacco taxation. Government officials responsible for toba excise and VAT planning and control, from a relatively low to the highest level, should be identified and sufficient regular contact maintained. while Ministerial (Government & Opposition) contacts should also be maintained to ensure that the Company is well placed to have its views taken into consideration when policy is being determined. Such contact should be the responsibility of senior management and the Board to ensure an adequate level and quality of communication. An amicable and effective partnership berwmn company and Government is the objective. Rather than reacting to a problem, a positive and pro-active approach to this subject must be implemented. Such reiations should establish BAT as the Company to which Government will turn when they need advice and assistance upon any aspect of excise taxation. which of course requires the existence of the knowledge and experience of excise in the Company. This is becoming more significant as our competitors seek to influence and change Government policy on excise structures from that which is appropriate to BAT to that which is more appropriate to their own brand mix. Conversely, we should examine the opportunities to change excise systems too, if indeed such a change would be beneficial. In either instance, Sood and regular Government relations are essential. In this same context, it is also relevant to maintain close contact with manufacturers of products also subject to excise taxation, particularly alcohol. where there are many excise similarities. 10. Intemational Trade Issues Inc:zzlsingly the influence of IMF and World Bank is being felt in the arm of excise tax and VAT issues. Operating company management must be aware of their role and seek to influence decisions from these bodies e.g. most often ad valorem systems are proposed by DAF/Warld Bank. because of their belief. often misguided, that such systems are the most simple and maximise Government revenues. If this is not in our favour we must lobby against the proposals. INIF/World Bank policies are mostly directed from Washington DC Lrl and Nfillbank will be establishing contacts there. in order to assist ope.mm- companies. The proposals of the GATT, in particular since rQ r"i I C) L-4 L-4 BATCo document for Province of British Columbia 23 April 1999 the conclusion of the Uruguay Round, and the implications for world trade wiU have an increasing impact on the tobacco business. Import tariffs are still an important element in indirect taxation, but the trend post Uruguay is rapidly moving towards a reduction of Mriffs and other barriers to free trade. To rely on such tax barriers to 'protect' an uncompetitive business would not be viable in the longer term. In the expanding global scenario whereby exports currently account for over 20% of BATCo cigarette sales, tariffs are an important indirect tax and comme-mial issue. Since most of our exports are of higher quality, higher price international brands, our policy in export markets is as follows: eliminate tariffs replace ad valorem tariffs with specific tariffs persuade Government to raise revenue through excise and other indirect taxation not rariffs lobby for specific or predominantly specific excise taxation, because ad valorem excise multiplies the amount of the tariff (a tax on a tax). It should also be pointed our that our policy on tariffs in domestic markets is generally the opposite of the above. In markets where BAT has a'~ominant share. or where competition is limited because restricted access to the market keeps out imports. out policy is to persuade Government to minimise imports through the application of high tariffs and other obstacles such as pre payment or early payment of excise taxes. (However, as noted above this is becoming more difficult.) 11. Industry Relations In a competitive context, tobacco excise taxation is a key subject for discussion and agreement in the National Manufacturers Association. Collective action and influence by the industry is likely to be more effective and productive than by individual companies, although the lamer may also be appropriate from time to time. Although the lead company on excise issues tends to select itself on the basis of market share, it can also be on the basis of knowledge, cotperience, contacts with Government- Where market share means that it is not BAT companies should seek to ensure a lead position through these other means. Excise contains many complex aspects which hive to be mastered if LIAI 1A leadership is to be established. cr, NJ r1 J CD 13 ATCO document for Province of British Columbia 23 April 1999 Although the main thrust on excise should and will always come from the manufacturers, some benefit may be deiived from incorporating natural allies such as tobacco farmers, processors, suppliers to the industry, distributors and retailers in the lobbying activities of the NMA on excise levels. Every opportunity for the industry to agree policy and act collectively shouid be taken. However, if agreement proves impossible, it will be necessary to devote the appropriate company resources to Government relations to ensure that the Group position and influence exceeds that of the competition. U. Competitor Monitoring BATCo policy is to comply with local excise legislation whmver we operate. In a number of countries. our competitors do not always have the same policy. In order that we are not at a competitive disadvantage evidence of avoidance or evasion should be advised to Government to ensure compliance. This is often an issue requiring delicate handling but the objective is clear. 13. Value Added Tax Value Added Taxes (VAT) are always ad valorem. Ideally they are charged on the supply, including importation, of goods and services at every stage up to sale to a final consumer. They are accounEs-based taxes. This limits their coverage, for example to manufacturers and wholesalers in countries where retailers do not keep accounts. Businesses required to charge and account for VAT are registered by the tax, authorities and required to keep specified accounts and make periodic returns of the ta., due. The tax due is the difference between the tax charged on sales and the tax paid on business purchases in the period. Excise duty periods and VAT periods need not coincide e.g. in some countries excise periods are monthly and VAT quarterly. 13 Ln C:) cr, CD L4 U1 BATCo document for Province of British Columbia 23 April 1999 In many countries, where Governments are not confident of wHecting all the VAT due from the wholesale or retail staged, manuftcturers are required to charge the = on wholesale or retail pri=. This can be advantageous; it depends on the length of credit; them can be cash flow benefitr, it gives manu&cmrcn a degree of control over retail prices. It is important, when VAT is applied to tobacco products, to seek to ensure : a) that excise rates are reduced in compensation b) dw the tax regime aHows the deduction of VAT on ;al business purchases c) that the length of credit adequately compensates for the costs of accounting for and coUccting the tax for the Government. d) that the collection of VAT does not extend beyond the manufacturing stage, uniess controlled by the manufacturer. as noted above. DJ Bishop ,Njarch 1994 L4 Lr- CD Nj cr, NJI r1 j CD LN C7 \ BATCo document for Province of British Columbia 23 April 1999 APPENDEXT STRUCTURF OF FXCIqV TAXATION 'rhe principle features, advantages and disadvantages of the main types of excise systems are: SPECIFIC A specific excise structure is most suited to a company whose brands hive high levels of added value ot image and are positioned in the high and premium price segments. Bemuse a specific structure results in only a narrow price range betwem the cheapest and the most expensive, there is little opportunity to compete an the basis of price. A specific structure is the global policy of Philip Morris whose brands art normally positioned &E the cop end of the market. Indeed, they lobby hard to change structures to specific and in some instances have succeeded, eg. Hong Kong. A specific excise structure is closely associated with hi-h levels of profitability and product quality. Z~ough many factors determine profitability', a key one is the nature and extent of price competition, the opportunities for which are limited with a specific structure. For example : A 8 C Retail price 100 89 111 Specific Excise 70 70 70 Trade Margin - 10% 10 9 11 Net Manufacturer Price 20 10 30 Th, is example demonstrates two features of & speciric structure based upon base case A: B A reduction of 50% in the manufacturer's net price from 20 to 10 results in an 11 % fill in the retail price thereby demonstrating the limited opportunity for price competition. C An incre= of 50 % in the manufacturer's net price from 20 to 30 results in only an I I% increase in the retail price thereby demonstrating how simple it is for a manufacturer to increm C) r11j CN r1 i r1 j C) L-4 13 ATCO document for Province of BritiSh Columbia 23 April 1999 profitability provided freedom to raise prices exists. For the same reasons as it discourages price competition. a specific structure tends to encourage high qualiEy products. A specific structure requires a positive act by Government to raise the level of taxation which may be difficult to achieve in a political coalition situation or where the opposition is strong. It may be difficult to achieve a wholly specific structure in some developing markets because of the resul=t limited price range which Governments may consider necessary to meet the divergent needs of smokers. In such instances, a predominantly specific structure should be the target- There are excise structures whose fearures am essentially specific but whose impact is the same as an ad valorem structure. This occurs when Government has different Specific taxes according to a particular 'siab'. The various slabs being determined by: length of cigarette or price of cigarette. A specific slab structure is to be preferred to an ad valorem slab structure. SPECIRC BY WEIGHT This method of taxing cigarettes originated in the United Kingdom whi:~ discontinued it when it joined the European Community. However, some countries still apply such a structure. Its features are different from the specific by number and the market impact can be different. although it remins the normal characteristics of a specific system. The tax might be assessed on the weight of tobacco used to manufacture the cigarettes e.g. Sri Lanka, or it can be on the weight of the finished product e.g. Australia. Singapore and Malaysia. One of the problems of this system is that it is administz-atively cumbersome. In addition, unless some form of credit is agreed for factory waste the front end weight system can be very costly. In Australia the system has encouraged fierce competition between the cigarette N; 011 NJ 16 U4 Ca 13 ATCo document for Province of British Columbia 23 April 1999 manufhcturers to reduce product weights and densities and hence prices. AD VALORDI The impact of ad valorem excise sm=re will vary according to the local circumsmnccs of a particular company. In a highly competitive market it may result in a significant degree of price competition and a resultant low level of profitability. However, in a monopoly or near monopoly market, it may not have the same results unless a new small competitor starts a price war. It will also depend upon many factors such as the recognition by Competitors and Gove-nment of the need for a profitable price structure to ensure the financial health of the manufacturers and the Ministry of Finance. An ad valorem excise structure creates or is best suited to a company whose brands are mainly located in the lower price segments, or a company whose costs of manufacture are significantly lower than the competition by virtue of a dominant market share. Such a structure enables low added value and low image brands to survive with a significant price advantage over the higher image brands. It also enables the advantage of lower costs to be passed on to the consumer with a 'multiplier' effect on the retail price. An ad valorem excise structure is frequently linked with lower levels of profitability because it creates the circumstances where price competition can flourish. However, there are many exceptions to this which demonstrates that many other factors need to be taken into account before such a general statement can be made. An ad valorem structure has a multiplier effect upon ex factory price differences which enables manufacutrers to reduce prices at the 'expense' of the Government instead of by reducing their own profit margins for e-xmple! A R C Retail Price 100 50 150 Q11 Ad Valorem Excise C) (70% of retail price) 0 35 105 r%.) Trade Margin cr, Nj NJ C:~ 17 BATCo document for Province of British Columbia 23 April 1999 (10% of retail price) 10 5 15 Net Manufacturers Price 20 10 30 nis example demonstrates two features of an ad valorem structure based upon a base caz A : B.A reduction in the manufacturer's net price by 10 units from 20 to 10 results in a decre= in the retail price of 50 units thereby showing the multiplier effect of an ad valorem excise structure. C.Similariy an incre;tse in the manufacturer's net price by 10 units from 20 to 30 results in an increase in the retail price of 50 units, thereby showing the multiplier effect in the context of an increase. T'he NIULTIPLIM concept occurs directly from an ad valorem structure. In the above me the multiplier has a value of 5 which means a net price change of 10 results in a remil prce change of 50. It is calculated as follows : 100 - X where x = the sum of the proportional elements expressed as pe-cenmgcs of the retail price. "A = SO = M = lm = BQ 100-(ad 100-(70+10) 100-80 ZO valorem. trade mar--ins) For the same rmson as it encourages price competition, an ad valorem structure can often lead to lower quality products whose lower costs can be passed on to Elie consumer in the form of lower prices where the reduction is multiplied through the tax structure. Is Ur C) N; CTI M.) Nj CD BATCo document for Province of BritiSh Columbia 23 April 1999 An ad valorern structure automatically increases the amount of excise when a manufacm= increases its prices. It therefore has an appeal to Government who may not therefore need to Wm any action to increase their revenues. On the other hand, because revenue yield depends on retail prices, them is a greater danger of Government interference in retail price detemination than there is when the excise is specific. In some markets ad valorem excise is expressed- as a percentage of the ex factory price and not the retail price. In such situations, it may be appropriate to consider transferring some of the elements nornully included in the ex factory price to beyond the point where the ad valorem 4 applied and so saving the multiplier effect impacting upon them. One means of achieving this is to transfer some of the marketing expenses. However, one should appreciate that this might be a short lived tactic which may give rise to problems with Government over the longer term and may enhance the power of the trade, particularly if thev margin were increased to absorb the transfer of marketing expenses. ,NMIED A mixed excise structure contains elements of both specific and ad valorem. Its effect clearly depends upon the relative size of the two elements. Such a system applies throughout the European Community although different countries have different relativities between the two. A mixed structure can be particularly beneficial to a company whose brand mix includes both higher priced brands and mid priced brands which am normally local or national. The exact balance or relativity between the two will depend very much upon the cost structure of a market and the retail price structure required. t9 C) r1 i CF\ rQ NJ C) -Ch- BATCo document for Province of BritiSh Columbia 23 April 1999 APPENDIX 11 rXCTr,E ADMMSTRATION There are many aspects of excise administration which have an impact upon the company. Although not all of them can be addressed in a key area paper, some are worthy of inclusion. TLNMNG OF PAYMENT It is important to establish exactly when excise taxation falls due, and when the clock starts for any excise credit granted by Governments. With banderoles or fiscal stamps, the timing of payment is normally based upon the actual purchase of the stamps, the time it takes to manufacturt: and deliver and the . porting stock durations of the manufacturers and the trade. Arguments and sup ' evidence are essential to persuade Governments to accept payment cnly when the cigare= have been sold to smokers or as a minimum when payment has been received by the manufacturen. With other systems of collecting. excise the same principles of the timing of payment apply although the issue of when delivery to the trade takes place oftem becomes more important (is it when goods move from a central to a regional depot or from the latter to the trade). This &[so his impLicajions for stock valuations. With regards to the date and day of payment, it is helpful to establish wheLher payment has to be with the Government in the form of a cheque, whether it has to be in their account or whether it has to be with them in the morning or at any time on that date. The time taken to clear a cheque = often be significant in cash flow terms. REFUNDS It is important to establish a procedure for refunds or non-payment either to deal with re=m from the trade, damaged goods or bad debts. The exact demils will relate to the method of payment but should take into consideration the following an entitlement to a credit or refund for all goods returned by the trade, at the rate of excise appropriate to them. it is perhaps unrealistic to expect any refund to be at a level higher than the excise actually paid although it might be administratively simpler to provide for refunds to be at the current excise rate. An entitlement to a credit for all goods damaged during the manufacturing process. up to the point at which they are distributed to the trade. U71 C:) r1 j C7 \ r1 j r\j 20 BATCo document for Province of British Columbia 23 April 1999 An entitlement to a credit for all bad debts with trade non-payment being shared on dz basis that the manufActurer bears the cost of the goods but the Governme= bears the excise mxation element. The transfer of ownership is often a crucW element in this area. Provisions for excise taxation and refunds are not always identical to those for value add-I tax (if applicable). Governments should be persuaded to apply the same provisions using the mom beneficial of the two. 21 Nj C:) Z:~.. LI4 13 ATCo document for Province of British Columbia 23 April 1999 BATCo document for Province of British Columbia 23 April 1999 666~ I!jdV CZ eiqLunloo LISII!JJ3 10 OOUIAOidiol luouunoop oojLvj3 Lr) z -7 08, C%l C"i Fx Ln BATCo document for Province of British Columbia 23 April 1999 f. A Ift Un C~ rIj CII M r,.~ rIj CD 0% 3~1 666~ IIAV CZ eiquunloo 4SIM.18 10 ODUIAOJd .101 lueLunoop oojLVB LO Ln L.-pen t. 7-~'j 31 ;-%;:- SO r._.n :E .7.f F~-- r7 l 4., -1- M Fla, Nit W- 3 ; 2" -:14- 4 ;te ..4~ 7 V rIj CD BATCo document for Province of British Columbia 23 April 1999 Ln C:) rIj (IN r*j rIj C) CO BATCo document for Province of British Columbia 23 April 1999