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# SENEGAL

**THE INVESTOR's ROADMAP -- A REASSESSMENT**

###### May 2002

Foreign Investment Advisory Service

International Finance Corporation (IFC)/World Bank (IBRD) Joint Office

TABLE OF CONTENT

[Page]{.smallcaps}

[ABBREVIATIONS and acronyms iii](#__RefHeading___Toc8460562)

[ANALYTICAL SUMMARY............ iv](#__RefHeading___Toc8460563)

[INTRODUCTION 1](#__RefHeading___Toc8460564)

[CHAPter I Taking stock of the situation \-- progress in REFORMS
5](#__RefHeading___Toc8460567)

[A. The Investor's Roadmap: Recap of Procedures
5](#__RefHeading___Toc8460568)

[B. An Assessment of the Plan of Action 9](#__RefHeading___Toc8460570)

[C. A Quantitative Assessment of Actions Impact
12](#__RefHeading___Toc8460572)

[CHAPTer II Explaining Recent
DEVELOPPEMENTS](#__RefHeading___Toc8460575) 17

[A. A Fragile and Changing Institutional
Framework](#__RefHeading___Toc8460576) 17

[B. The Absence of Performance Criteria](#__RefHeading___Toc8460577) 19

[C. A Lethargy inherent to the basic problems of Senegal's
Economy](#__RefHeading___Toc8460578) 19

[D. An Incomplete Diagnosis](#__RefHeading___Toc8460580) 23

[CHAPter III RECOMMeNDATIONS](#__RefHeading___Toc8460581) 25

[A. Enhancing the Plan of Action](#__RefHeading___Toc8460582) 26

[1. General Formalities](#__RefHeading___Toc8460584) 29

[2. Sectoral Licensing](#__RefHeading___Toc8460585) 33

[3. Access to Lands and Site Layout](#__RefHeading___Toc8460586) 36

[4. Operational Formalities](#__RefHeading___Toc8460587) 45

[B. Reinforcing the Reform Process](#__RefHeading___Toc8460588) 48

[1. The Institutional Framework](#__RefHeading___Toc8460589) 48

[2. Adoption of Performance Criteria](#__RefHeading___Toc8460591) 54

[3. An Incentive Mechanism](#__RefHeading___Toc8460592) 55

[C. Assessing Financial Needs](#__RefHeading___Toc8460593) 57

[1. Funding the Secretariat](#__RefHeading___Toc8460594) 58

[2. Logistic Support to Two Priority
Projects](#logistic-support-to-two-priority-projects) 58

[3. Technical Support to and Training of Administrative
Departments](#technical-assistance-and-training-in-administration) 59

ABBREVIATIONS AND ACRONYMS[]{#__RefHeading___Toc8460562 .anchor}

APIX National Investment Promotion Agency

CCRA Canada Customs and Revenue Agency

CFE Company Formality Center

CGCD General Development Advisory Committee

CSS Social Security Fund

DAU Urban Planning Department

DGI Internal Revenue Head Office

DGID Internal Revenue and State Property Head Office

DMT Workers' Movement Declaration

FIAS Foreign Investment Advisory Service

GIE Economic Interest Grouping

GRCC Study Group on Competitiveness and Growth

IPRES Senegal Provident Fund

NINEA National Company and Association Registration Number

OE Company Opening

OMC World Trade Organization

PME Small and Medium-sized Enterprises

SENELEC National Power Supply Company

SODIDA Dakar Industrial Zone Company

SONATEL National Telecom Company

SONES Senegal National Water Supply Company

TIC Tanzanian Investment Center

UEMOA West African Economic and Monetary Union

UPE Economic Policy Unit

OHADA. Organization for the Harmonization of Business Law in Africa

ONAS Senegal National Drainage Company

SDE Senegal Water Supply

ZFI Export Processing Free Zone

ANALYTICAL SUMMARY[]{#__RefHeading___Toc8460563 .anchor}

i.  Investors have to face time-consuming and complex administrative
    procedures in Senegal. As a result, companies are reluctant to set
    up business in Senegal and to expand across the country. The local
    small and medium-sized enterprises are also forced to remain in the
    informal sector due to lengthy administrative procedures. The
    latter's impact is all the more negative as Senegal's investment
    environment offers a number of advantages such as political and
    macro-economic stability. Investors are therefore surprised by these
    administrative formalities which it often takes more than two years
    to fulfill*. "Time is money and time can be particularly long in
    Senegal"*.

ii. The is nothing new. The same observation had led to the realization
    of the first FIAS study in 1998 and the adoption by the Ministerial
    Council of a Plan of Action in 1999. Since then, this plan has
    become a focal point in the preparation of the private sector
    development strategy in which the *"State clearly affirms its will
    to simplify procedures and to reduce the related costs for
    enterprises"*.[^1]

iii. In this context and four years later, the Government of Senegal
     requested FIAS to make an assessment of the progress made so far
     and to possibly identify the constraints that have delayed the
     implementation of the Plan of Action. The ultimate objective is to
     make a set of recommendations aimed at improving the initial
     diagnosis and stepping up the reform process.

iv. FIAS adopted a dual approach. First, it updated the investor's
    administrative roadmap as identified in 1998. FIAS held talks with
    the relevant departments and the main system users such as company
    advisers, notaries and chartered accountants. Secondly, FIAS
    surveyed 184 companies in order to grasp the current perceptions and
    constraints of the private sector (the detailed survey is attached
    as Appendix A).

    **Taking stock of the situation in 2002**

v.  The Plan of Action adopted in 1999 contained thirty four measures to
    streamline administrative procedures. They were the result of a
    dialogue instigated by the Prime Minister's Office across the
    various administrations and departments and related to four
    categories of procedures viz.:

-   general entry formalities consisting mainly of a variety of
    registrations with the Trade Register and the Taxation Authorities,
    licensing under the Investment Code and approval of the immigration
    and work permit delivery departments;

-   specialized licensing which is required for those who want to invest
    in particular sectors such as tourism, mining, fishery, etc;

-   land access procedures, site layout and connection to basic
    infrastructures such as telephone and power supply;

-   operational formalities such as foreign exchange and import/export
    operations and a variety of sanitary and labor inspections to which
    operating companies are subjected;

    i.  In March 2002, FIAS noted that about fifteen out of the thirty
        four measures had been partly or totally implemented by the
        Government (that is, about 40% of total). This mixed achievement
        needs to be commented upon. It is indeed important to mention
        that most of the measures came under the general formalities
        area with an improved operation of the Single Window and under
        operational formalities. On the other hand, for the past four
        years, there have been only little changes in land access and
        site layout procedures as well as specialized licensing
        procedures.

    ii. The lack of progress in the last two categories explains why the
        investor's administrative roadmap is certainly longer today than
        in 1998. Below are the main lessons drawn from FIAS' analysis:

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-   the time required for the investor to complete the administrative
    roadmap in Senegal as reported by the relevant official departments
    increased on average from 495 to 563 working days between 1998/1999
    and 2002;

-   the significant progress witnessed in the fulfillment of the general
    and operational formalities does not offset time extension for
    access to land, site layout and connection to the main basic
    infrastructures;

-   the time required to complete the administrative roadmap in Senegal
    is longer than the average in twenty African countries, in
    particular, because of the difficulty to secure access to land. Only
    Mozambique and Tanzania exhibit longer waiting times than Senegal in
    this category. These performances are far weaker than the waiting
    times reported for the most performing countries of South East Asia
    or OECD;

    i.  This bad news means that the investor spends more waiting time
        and the company survey outcome confirms that only 16% of such
        companies are satisfied or very satisfied with the
        administration's behavior. For 70% of the companies surveyed,
        administrative obstacles constitute an hindrance to their
        development, which is higher than the reported rates of
        financing and infrastructure access constraints (however, when
        the latter do exist, they appear to be more serious).

    ii. It is not surprising that the waiting times associated with
        administrative procedures in Senegal encourage companies to look
        for alternatives. Bigger companies have recourse to advisers to
        help them speed up fulfillment of formalities by their knowledge
        of the system and people. Smaller companies just decide to
        remain in the informal sector. Besides, already established
        companies receive a preferential treatment compared to new
        comers who have to go through entry formalities. In short,
        administrative procedures not only cause considerable delays for
        companies but they also give rise to unequal treatment and
        frustrations, leading to corruption both in the public and
        private sectors.

        **Reasons to explain this mixed achievement**

    iii. There are many reasons to explain this mixed achievement in the
         implementation of the Plan of Action in Senegal. First is the
         unstable institutional framework that accompanied the reforms.
         For the past four years, the Plan of Action has been placed
         successively under the responsibility of the Prime Minister,
         the Minister of Finance and Economy and APIX. This instability
         has prevented good coordination within the public
         administration and reduced program visibility and support over
         time both by politicians and the private sector. It appeared
         indeed that the participation of the private sector has been
         relatively reduced as opposed to its initial commitment to
         reforms.

    iv. The second reason is the absence of performance criteria. The
        Plan of Action adopted in December 1999 focused on the
        administrative and legal measures called for to streamline
        existing formalities. Emphasis was placed on the actions that
        needed to be undertaken and not on the results expected from the
        investor's roadmap. This is an important oversight because very
        often, changes in the legislative texts do not translate into
        reality. Besides, FIAS noted that it was difficult for the
        authorities to follow up and to adequately assess the real
        implications of the measures adopted in the absence of
        performance criteria. Adopting performance criteria would have
        probably facilitated the follow up of proposed measures, making
        it possible to compare Senegal's performance over time and with
        that of other countries and thus motivate the departments
        concerned and politicians.

    v.  The third reason is that the streamlining of administrative
        procedures is linked to progress in the country's economic
        structures and policies. While in some cases, a simple
        bureaucratic change is enough to reduce an administrative
        formality, very often the bureaucratic red tape can be explained
        by the more general context of the country. FIAS identified
        three factors that contributed to slowing reform implementation:

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-   slow-paced legal changes even where they have been accepted at the
    technical level. For example many measures have been hindered by
    legislative slowness as in the adoption of the new Mining Code and
    Investment Code (at the WAEMU level);

-   many actions depended on the adoption of economic policy reforms on
    which consensus is yet to be reached both at the technical and
    political levels. Thus, the little progress noted in the measures
    aimed at facilitating access to land or site layout can be partly
    explained by the fact that no progress was recorded in land policy
    and decentralization in the past few years. Similarly, the
    administrative slowness noted in terms of connections to public
    utilities are to be linked to the privatization policy;

-   an administrative reform generally requires a change in the behavior
    and mentality of system users. In this context, apparently the
    success of the reforms aimed at streamlining the investor's roadmap
    in Senegal strongly depends on the government's capacity to reduce
    corruption and enhance State governance. Streamlining administrative
    procedures should clearly be part of the efforts aimed at fighting
    corruption and reforming the Senegalese civil service.

    i.  Lastly, the fourth and last reason is that the diagnosis made in
        1998/1999 was incomplete. This gap is particularly visible in
        the category of measures related to access to land and site
        layout which have also witnessed the least progress in the past
        few years.

        **Recommendations**

    ii. FIAS suggests two types of recommendations to improve the
        implementation of the Plan of Action. First, it recommends that
        the initial diagnosis be refined by proposing additional
        procedure streamlining measures. Next, it is essential to
        enhance the process by which the procedures will be put in
        place. This second aspect is important as efforts to streamline
        administrative procedures are dynamic in essence and must take
        into consideration the political, institutional and legislative
        changes that are bound to occur over time. In conclusion, FIAS
        proposes a brief description of the financial resources needed
        to back up this streamlining effort.

        *Enhancing the Plan of Action*

    iii. The starting point is certainly to demonstrate the Government's
         political will to streamline administrative procedures. The
         Plan of Action made provision for "the adoption of an
         Investment Procedure Facilitation Act the basic objective of
         which was to attempt to establish a clear and complete doctrine
         on investment procedure facilitation". The first recommendation
         is therefore to adopt such a legislation. The Senegalese
         Authorities might be inspired by the French Law n° 2000-321,
         dated April 12^th^ 2000, which requires administrations to
         respond to a user's application within a prescribed time.

    iv. While the Government's will should be asserted, the Plan of
        Action should also be refined. Many actions need to be updated
        or further detailed while others are simply absent from the
        initial diagnosis;

    v.  The summary of all FIAS' recommendations is included in the main
        report (see Table III-I). We would simply recall here that while
        recommendations cover all administrative formalities, they focus
        more on the access to land and site layout category.
        Recommendations are often followed with references to best
        international practices, as applicable.

        *Process Reinforcement*

    vi. The process of streamlining administrative procedures must be
        reinforced. FIAS recommends that the institutional framework be
        enhanced, that performance criteria be established and that
        incentive mechanisms be set up to encourage reforms. These three
        aspects are summarized hereinafter:

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-   [Enhancing the institutional framework]{.underline}. International
    experience has demonstrated that the institutional framework is
    generally made up of 4 components: a) the Decision-making Center; b)
    the Advisory Council; c) the Secretariat; and d) the Technical
    Groups. The role and functions of each of these components are
    detailed in the report, and on this basis, proposals have been
    developed for the Senegalese context. A special attention has been
    devoted to the relationship between these different components and
    to the operation of the Secretariat.

-   [Establishing performance criteria]{.underline}. The main
    performance criterion would be to set quantitative objectives in
    terms of reducing the waiting times associated with some of the
    procedures such as, for example, company registration or hotel
    inspections. These objectives might be set on the basis of the
    current waiting times identified in the company survey. Others might
    be established in relation to best international practices. It is
    important to agree both on the quantitative objectives and the
    methodologies that will be used to assess them. Many proposals have
    been developed in the report, notably outcome publishing and
    periodic company surveys.

-   [Setting up incentive mechanisms]{.underline}. As incentive
    mechanisms, FIAS recommends the adoption of a surveillance and
    compensation policy. The surveillance policy should be used by the
    decision-making center precisely to ensure that the measures
    identified in the Plan of Action are promptly implemented by the
    administrative departments concerned. An additional approach would
    be to reinforce result transparency by diffusing the performances of
    administrative departments within the administration and among the
    public. Transparency makes it possible to identify good and bad
    results. While a surveillance policy is necessary, it does not
    suffice to achieve any results in the medium and long terms. It is
    also essential to set up mechanisms designed to reward the
    departments or civil servants that have implemented the Plan of
    Action and have thus contributed to an improved investor's roadmap.
    Like in any reform process, it is useful to identify "winners"
    because there will always be "losers" who will try to maintain a
    status quo. Incentive mechanisms may be of a technical or financial
    nature.

    *Estimating financial needs*

    i.  The implementation of the Plan of Action requires a political
        and financial commitment by the Government as many measures will
        require the modernization of the systems used by the
        administration and some training with a view to backing up
        behavioral and technical changes within the departments
        concerned. In the case of Senegal, this financial support may
        come not only from Senegal but also from the donors who have
        demonstrated a strong determination to accompany the authorities
        in their effort to streamline the country's administrative
        procedures.

    ii. The proposed estimate of financial needs can only be a
        preliminary one. It will necessarily have to be complemented on
        finalizing the Plan of Action and when the Secretariat becomes
        really operational. Obviously, this should be one of the first
        duties of the Secretariat. In this context, three priorities
        have been discussed in the report, viz. a) Funding of the
        Secretariat; b) Logistic Support to the Formality Center and to
        the Land Registry, which will constitute two priority projects
        in the reform schedule; c) Technical or Training Support which
        must accompany many actions taken at the administrative
        department level.

    iii. The financial needs of the administrative procedure
         streamlining program should remain limited especially when
         compared to the expected benefits. For example, it is important
         to point out that each 10% reduction in the average cost of
         each administrative procedure may raise direct foreign
         investment flows into a country by about 5%.[^2]

INTRODUCTION[]{#__RefHeading___Toc8460564 .anchor}

1.  In the past decade, the Government of Senegal pursued a development
    strategy in which the private sector was led to play a central role.
    In this vision, the promotion of private investment became a crucial
    element and the number of initiatives increased. Most of the
    State-owned companies were privatized, the Investment Promotion
    Agency (APIX) was established and many economic policy reforms aimed
    at enhancing the business environment were put in place, notably at
    the regional level such as the customs reform within the West
    African Economic and Monetary Union (WAEMU) and the reform of the
    business legal framework supported by OHADA.

2.  At the end of the 1990s, it appeared that the promotion of private
    investment in Senegal is hindered by a series of administrative
    obstacles. The Senegalese bureaucratic red tape is indeed
    responsible for long and frequent delays for companies which are
    interested in setting up business in the country. As a result,
    foreign investors choose an alternative location for their projects
    while local investors prefer to remain in the informal sector. Even
    where these obstacles can be side-stepped, they remain a source of
    discontent because they favor unequal treatment. In a country which
    enjoys a good political and macroeconomic stability like Senegal,
    administrative obstacles assume unexpected proportions, for
    investors are quickly discouraged when they find out on their
    arrival that it will take them almost two years to fulfill all the
    country's official formalities. "Time is money" and time was
    particularly long in Senegal.

3.  This observation is not surprising and it is confirmed by a survey
    of 184 private sector companies in April 2002 (see Appendix A for a
    description of the survey). More than 71% of the companies believe
    administrative obstacles to be a constraint to the development of
    the private sector, making this obstacle rank first just ahead of
    the paperwork burden and taxation system complexity. Administrative
    obstacles appear on average to be a more important constraint than
    funding, basic infrastructure, macroeconomic environment and
    political stability (see Table 1). This diagnosis, however, needs to
    be somewhat qualified owing to the fact that when a company faces
    funding and infrastructure problems, these are perceived to be of a
    more serious nature than administrative procedures.

Table 1: Main Constraints to Private Sector Development

\- Results of Survey (as a % of Companies Interviewed)

+------------------------------+----------+-------------+-------------+
|                              | O        | Of which :  | Average and |
|                              | bstacles |             | Minor       |
|                              |          | Serious and |             |
|                              |          | Important   |             |
+------------------------------+----------+-------------+-------------+
| Administrative Procedures    | 71.7%    | 29.3%       | 42.4%       |
+------------------------------+----------+-------------+-------------+
| Paperwork & Taxation System  | 71.2%    | 45.7%       | 25.5%       |
| Complexity                   |          |             |             |
+------------------------------+----------+-------------+-------------+
| Illegal and Informal         | 67.9%    | 51.1%       | 16.8%       |
| Competition                  |          |             |             |
+------------------------------+----------+-------------+-------------+
| Access to Funding and Cost   | 67.4%    | 53.0%       | 14.4%       |
+------------------------------+----------+-------------+-------------+
| Lack of Infrastructure       | 65.6%    | 35.5%       | 30.1%       |
+------------------------------+----------+-------------+-------------+
| Corruption                   | 57.6%    | 29.1%       | 28.5%       |
+------------------------------+----------+-------------+-------------+
| Macroeconomic Environment    | 56.5%    | 25.5%       | 31.0%       |
+------------------------------+----------+-------------+-------------+
| Access to Land               | 54.9%    | 29.9%       | 25.0%       |
+------------------------------+----------+-------------+-------------+
| Political Instability        | 48.9%    | 21.7%       | 27.2%       |
+------------------------------+----------+-------------+-------------+

Source : (APIX and FIAS) Survey, 2002

4.  More generally, the negative impact of excessive administrative
    costs on investment notably foreign investment has been highlighted
    in many countries and popularized by H. de Soto's [^3] books. Chart
    1 hereinafter reveals that countries with the lowest administrative
    costs -- in terms of waiting time and financial costs -- have
    attracted the highest volume of foreign investments. This negative
    relation has prompted reform efforts to reduce administrative
    formalities in many countries -- both industrialized and developing
    ones, in recent years.

5.  The same arguments had led in 1998 the Government to call on the
    Foreign Investment Advisory Service (FIAS according to the English
    abbreviation) to look into the administrative roadmap which an
    investor had to follow to set up business and operate in Senegal.
    This survey had been discussed by the main actors involved -- both
    from the private and public sectors -- at a workshop held in
    December 1998[^4] and had led to the preparation of a Plan of Action
    approved by the Ministerial Council in December 1999. This Plan of
    Action was later integrated in the private sector development
    strategy drawn up by the Government and approved by donors in
    Senegal.[^5]

Chart 1 : The Negative Impact of Administrative Costs on Direct Foreign
Investment: A Country Comparison

> ![](media/image2.wmf)Source : Morisset and Lumenganeso (2002)
>
> Footnote: This is a comparison of 32 developing countries including 20
> African countries. Direct foreign investment is defined as flows to
> each country in US\$ and as a percentage of GDP while administrative
> costs combine official costs and delays caused by each administrative
> procedure in each country and as a percentage of their GDP.

**An Assessment of the Plan of Action: 4 Years Later**

6.  Almost four years later, Senegalese Authorities wonder about
    progress in the implementation of the Plan of Action. This resolve
    to pursue the efforts initiated is reflected in the recent private
    sector development strategy in which *"the State clearly affirms its
    will to simplify procedures and to reduce their related costs for
    companies* [^6]*"*

7.  More specifically, the Authorities are asking the following
    questions:

-   What progress has been achieved over the past few years?

-   Did the implementation of the plan translate into an effective
    enhancing of the investor's roadmap in terms of cost reduction and
    shorter waiting times?

-   Where does Senegal stand in relation to the other developing
    countries particularly in the region?

    1.  The objective of this study is to provide answers to these
        questions. The analysis is divided into three chapters. Chapter
        1 starts with a brief survey of the current situation by
        comparing the investor's administrative roadmap in early 2002
        with the one identified in 1998. Following this assessment, a
        qualitative and quantitative appraisal of progress in reforms is
        proposed. We not only verify whether the measures have been
        adopted but we also try to evaluate their real impact on the
        time investors have to spend going through the procedures.
        Senegal's performance over time is proposed and compared with
        that of many other countries.

    2.  In Chapter II, we try to understand the reasons explaining
        recent developments especially the very slow pace of some
        reforms. The recommendations proposed in the last chapter will
        be based on identified factors.

    3.  The third and last Chapter will be devoted to recommendations
        aimed at improving and expediting the streamlining of
        administrative procedures. The focus is successively on the need
        for an improved diagnosis and the initial Plan of Action
        especially with respect to land development procedures and on
        the reinforcement of the reform process. Many recommendations
        aim at developing an appropriate institutional framework,
        adopting (quantitative) performance criteria along with an
        incentive mechanism which would further motivate the
        administrative departments concerned.

    4.  It is important to mention that efforts to streamline
        administrative procedures are part of the Government's larger
        ongoing endeavor to enhance the business environment in Senegal.
        This interconnection between administrative reforms and economic
        policy reforms will be highlighted throughout the report. It
        will support the fact that even though progress in the
        investor's administrative roadmap may often appear to be trivial
        at first sight, it actually touches on the country's basic
        points such as the civil service or the taxation and trade
        policy and requires constant support from the Highest
        Authorities of the Government.[^7]

CHAPTER I[]{#__RefHeading___Toc8460567 .anchor}

TAKING STOCK OF THE SITUATION \-- PROGRESS IN REFORMS

5.  The purpose of this chapter is to compare the investor's
    administrative roadmap in Senegal as reported in FIAS' first survey
    in 1998 and the current situation. This will enable us to assess the
    progress made by Senegal over the past four years and to determine
    its performance in relation to those of other countries in the
    sub-region. It will also allow us to identify the formalities that
    still pose problem and on which the Authorities need to focus their
    attention.

6.  We divided our approach into the following stages. In a first stage,
    we give a brief summary of the procedures identified in the
    investor's roadmap in 1998 followed by a description of the current
    situation. It is important to mention that to make the presentation
    short, the details associated with each procedure are presented in
    Appendix B. Next, we try to determine to what extent the Plan of
    Action approved in December 1999 has been implemented by classifying
    the administrative, legislative and regulatory measures adopted by
    the Authorities in the past few years. A first observation can thus
    be made on whether the reforms were successful.

7.  We completed our approach with a third stage in which we proposed a
    quantitative evaluation of progress made. In fact, the duration of
    each procedure is compared between 1998/99 and 2002. Such an
    exercise is useful to assess the real impact of reforms over time
    and to compare Senegal's current performance with those of other
    countries in the sub-region.

    A. The Investor's Roadmap: Recap of Procedures
    []{#__RefHeading___Toc8460568 .anchor}

8.  The administrative roadmap that an investor must follow is similar
    to that of 1998/1999, making the comparison easier. While some
    formalities have been modified as reported further herein, none of
    them were dropped.[^8] Roughly, the investor's roadmap is divided
    into four categories which can be described as follows:

-   *General entry formalities* consisting mainly of a variety of
    registrations with the Trade Register and the Taxation Authorities,
    licensing under the Investment Code and the approval of the
    immigration and work permit delivery departments.

-   *Specialized licensing* which is required for investments in
    particular sectors such as tourism, mining, fishery etc.

-   Mandatory procedures for *access to land,* site layout and
    connection to a variety of basic infrastructures such as telephone
    and power supply.

-   *Operational formalities* such as foreign exchange, import/export
    operations and a variety of sanitary and labor inspections to which
    operating companies are subjected.

    1.  The above-mentioned four categories cover most of the procedures
        that an investor must follow to set up business and operate in
        Senegal. Some of the procedures are not mandatory including
        licensing under the Investment Code while others are specific to
        some categories of investors (For example, immigration
        formalities are required only for foreigners). It is important
        to note that the investor is assumed to be doing this through
        official channels as described by the laws or regulations and
        that he/she is not given any preferential or non-preferential
        treatment.

    2.  Below is a synthetic Table showing all the administrative
        procedures included in the investor's roadmap in Senegal. Each
        procedure is presented with the corresponding administrative
        department and a brief description of required documents.
        Details can be found in Appendix B.

Table I-1: Investor's Roadmap: A Summary of the Main Formalities

+-------------------------------+------------+-------------------------+
|                               | **Contact  | **Documents Required**  |
|                               | Point**    |                         |
+-------------------------------+------------+-------------------------+
| **GENERAL FORMALITIES**       |            |                         |
+-------------------------------+------------+-------------------------+
| Licensing under the           | Single     | Licensing application   |
| Investment Code               | Window     | form, list of capital   |
|                               |            | goods to be exempted    |
|                               |            | from customs duties,    |
|                               |            | company statutes, trade |
|                               |            | register registration   |
|                               |            | declaration form, copy  |
|                               |            | of ID card, minutes for |
|                               |            | EIGs.                   |
|                               |            |                         |
|                               |            | .                       |
+-------------------------------+------------+-------------------------+
| Company Registration          | Commercial | Three filled copies of  |
|                               | Court      | "Registration           |
|                               |            | Declaration Form"; two  |
|                               |            | certified true copies   |
|                               |            | of company statutes;    |
|                               |            | two copies of the       |
|                               |            | certified true list of  |
|                               |            | managers, executive     |
|                               |            | directors or            |
|                               |            | associates; two copies  |
|                               |            | of the managers,        |
|                               |            | executive directors or  |
|                               |            | associates' police      |
|                               |            | record; a CFAF 2000     |
|                               |            | worth revenue stamp to  |
|                               |            | be stuck on the         |
|                               |            | registration            |
|                               |            | certificate.            |
+-------------------------------+------------+-------------------------+
| Taxpayer's Account N° (NINEA) | Internal   | Registration            |
|                               | Revenue    | application form, TR,   |
|                               | and State  | registration            |
|                               | Property   | declaration form,       |
|                               | Head       | company statutes,       |
|                               | Office     | lease, NINEA, [patent   |
|                               |            | tax payment]{.mark}     |
|                               |            | certificate, revenue    |
|                               |            | stamp.                  |
+-------------------------------+------------+-------------------------+
| Affiliation to the Social     | CSS        | Registration            |
| Security Fund (CSS)           |            | application form,       |
|                               |            | certificate bearing the |
|                               |            | taxpayer's account n°,  |
|                               |            | photostat copies of     |
|                               |            | company statutes,       |
|                               |            | company opening         |
|                               |            | notification form,      |
|                               |            | workers' movement       |
|                               |            | declaration signed by   |
|                               |            | the labor office, pay   |
|                               |            | book initialed by the   |
|                               |            | commercial court, NINEA |
|                               |            | N°, photostat copy of   |
|                               |            | the Trade Register,     |
|                               |            | registration            |
|                               |            | certificate.            |
+-------------------------------+------------+-------------------------+
| Affiliation to Senegal        | IPRES      | Photostat copy of the   |
| Provident Fund (IPRES)        |            | Trade Register,         |
|                               |            | photostat copy of       |
|                               |            | company statutes,       |
|                               |            | establishment           |
|                               |            | declaration signed by   |
|                               |            | the Labor Inspection    |
|                               |            | and Social Security     |
|                               |            | Service, Workers'       |
|                               |            | movement declaration    |
|                               |            | signed by the Labor     |
|                               |            | Office, employer's      |
|                               |            | staff register where    |
|                               |            | company employs more    |
|                               |            | than ten salaried       |
|                               |            | staff, each employee's  |
|                               |            | employment contract     |
|                               |            | signed by the relevant  |
|                               |            | Labor Inspection,       |
|                               |            | photostat copy of       |
|                               |            | NINEA.                  |
+-------------------------------+------------+-------------------------+
| Company Opening (CO)          | Ministry   | Establishment           |
|                               | of Labor   | declaration, NINEA.     |
|                               | and        |                         |
|                               | Employment |                         |
+-------------------------------+------------+-------------------------+
| Foreigner's ID Card           | Ministry   | Police record, medical  |
|                               | of         | certificate, birth      |
|                               | Interior   | certificate,            |
|                               |            | handwritten             |
|                               |            | application, photostat  |
|                               |            | copy of passport,       |
|                               |            | photos, revenue stamp.  |
+-------------------------------+------------+-------------------------+
| Investment registration       | Money and  | Plain letter.           |
|                               | Credit     |                         |
|                               | Department |                         |
+-------------------------------+------------+-------------------------+
| Registration of brand and     | SPIT/OAPI  | Precedence              |
| patents                       |            | investigation,          |
|                               |            | registration form,      |
|                               |            | payment receipt.        |
+-------------------------------+------------+-------------------------+
| **SPECIALIZED LICENSING**     |            |                         |
+-------------------------------+------------+-------------------------+
| Mining                        | Mining     | (mining permit) Legal   |
|                               | Department | entity (head office,    |
|                               |            | registered capital,     |
|                               |            | surnames and first      |
|                               |            | names, occupation,      |
|                               |            | nationality and         |
|                               |            | residence address of    |
|                               |            | anyone who holds a      |
|                               |            | responsibility in       |
|                               |            | company management such |
|                               |            | as the Chairperson,     |
|                               |            | managers, board members |
|                               |            | etc. statutes,          |
|                               |            | operating accounts and  |
|                               |            | balance sheet of last   |
|                               |            | financial year).        |
|                               |            | Identity of field       |
|                               |            | workers; purpose of     |
|                               |            | proposed mining, its    |
|                               |            | scientific or economic  |
|                               |            | character, its          |
|                               |            | geographic location and |
|                               |            | estimated duration; a   |
|                               |            | description of proposed |
|                               |            | projects and methods to |
|                               |            | be used.                |
+-------------------------------+------------+-------------------------+
| Tourism                       | Ministry   | Travel agency           |
|                               | of Tourism | licensing: a licensing  |
|                               | and APIX   | application to be sent  |
|                               | (hotels)   | to MTTA ; a Senegalese  |
|                               |            | nationality             |
|                               |            | certificate; a police   |
|                               |            | record dated less than  |
|                               |            | three months; a copy of |
|                               |            | lease or ownership of   |
|                               |            | premises; a pledge to   |
|                               |            | pay CFAF 500,000 worth  |
|                               |            | tourist deposit; a      |
|                               |            | civil liability         |
|                               |            | insurance coverage      |
|                               |            | receipt; a list of      |
|                               |            | permanent Senegalese    |
|                               |            | staff who must make up  |
|                               |            | at least 80% of the     |
|                               |            | salaried staff; a copy  |
|                               |            | of the certificate of   |
|                               |            | registration with the   |
|                               |            | Trade register, a copy  |
|                               |            | of company statutes; a  |
|                               |            | morality report         |
|                               |            | established by the      |
|                               |            | Ministry of Interior at |
|                               |            | the request of MTTA.    |
|                               |            |                         |
|                               |            | Hotel: a letter of      |
|                               |            | intent to be sent to    |
|                               |            | the Ministry of         |
|                               |            | Tourism; a feasibility  |
|                               |            | study;                  |
|                               |            |                         |
|                               |            | an architectural plan;  |
|                               |            | a copy of lease and     |
|                               |            | ownership.              |
+-------------------------------+------------+-------------------------+
| Insurance Companies/Banks     | BCEAO      | Banks: full application |
|                               | /Insurance | containing detailed     |
|                               | Department | information on          |
|                               |            | shareholders and the    |
|                               |            | bank project.           |
|                               |            | Insurance: same.        |
+-------------------------------+------------+-------------------------+
| Industry                      |            |                         |
+-------------------------------+------------+-------------------------+
| Technology                    | Dakar      | Licensing application,  |
|                               | Technopole | investigation by        |
|                               |            | Technopole.             |
+-------------------------------+------------+-------------------------+
| Fishery                       | Fishery    | Fishery licensing:      |
|                               | and        | fishery licensing form  |
|                               | Oc         | delivered by the        |
|                               | eanography | Oceanography and        |
|                               | Department | Maritime Fishing        |
|                               |            | Department, tonnage     |
|                               |            | certificate, single     |
|                               |            | window certificate or   |
|                               |            | Trade Register          |
|                               |            | certificate, company    |
|                               |            | statutes.               |
+-------------------------------+------------+-------------------------+
| Leather goods                 | Livestock  | Tanning licensing:      |
|                               | Department | installations plan,     |
|                               |            | copy of registration    |
|                               |            | with the Trade Register |
|                               |            | and written             |
|                               |            | application.            |
+-------------------------------+------------+-------------------------+
| Arts and crafts               | Arts and   | Establishment of        |
|                               | crafts     | cooperatives:           |
|                               | Department | comprehensive file on   |
|                               |            | promoters and project,  |
|                               |            | identity documents.     |
+-------------------------------+------------+-------------------------+
| **ACCESS TO LANDS AND         |            |                         |
| LAYOUT**                      |            |                         |
+-------------------------------+------------+-------------------------+
| Acquisition of public lands   | Internal   | Written application,    |
|                               | Revenue    | copy of plot plan,      |
|                               | and State  | investment program,     |
|                               | Property   | financing plan.         |
|                               | Head       |                         |
|                               | Office     |                         |
+-------------------------------+------------+-------------------------+
| Acquisition of private lands  | Notary +   | Verification of land    |
|                               | Internal   | title, bill of sale,    |
|                               | Revenue    | registration fee,       |
|                               | and State  | establishment of a new  |
|                               | Property   | ownership (if land is   |
|                               | Head       | divided up)             |
|                               | Office     |                         |
+-------------------------------+------------+-------------------------+
| Acquisition of industrial     | SODIDA     | Written application,    |
| lands in Dakar                |            | investigation by        |
|                               |            | SODIDA.                 |
+-------------------------------+------------+-------------------------+
| Export processing Free Zone   | ZFI        | Authorization suspended |
|                               |            | since 1999.             |
+-------------------------------+------------+-------------------------+
| Site Layout                   | Regional   | Written application,    |
|                               | Town       | building project, land  |
|                               | Planning   | title, land registry    |
|                               | Office     | certificate,            |
|                               |            | information             |
|                               |            | form, descriptive       |
|                               |            | estimate, town planning |
|                               |            | tax payment receipt,    |
|                               |            | revenue stamp.          |
+-------------------------------+------------+-------------------------+
| Environment                   | E          | Description of          |
|                               | nvironment | activity, site plan,    |
|                               | and        | block plan,             |
|                               | Classified | installations plan.     |
|                               | Companies  |                         |
|                               | Department |                         |
+-------------------------------+------------+-------------------------+
| Power supply                  | SENELEC    | Subscription            |
|                               |            | application form, ID    |
|                               |            | card, Trade Register.   |
+-------------------------------+------------+-------------------------+
| Telecommunications            | SONATEL    | Subscription            |
|                               |            | application form, ID    |
|                               |            | card, Trade Register.   |
+-------------------------------+------------+-------------------------+
| Drinking water                | SdE (Water | Connection application  |
|                               | supply)    | form, ID card, title of |
|                               |            | ownership or lease.     |
+-------------------------------+------------+-------------------------+
| Drainage                      | ONAS       | Connection application  |
|                               |            | form.                   |
+-------------------------------+------------+-------------------------+
| Mail                          | Post       | Post office box rental  |
|                               | office     | application form,       |
|                               | Head       | company statutes.       |
|                               | Office     |                         |
+-------------------------------+------------+-------------------------+
| **OPERATIONAL FORMALITIES**   |            |                         |
+-------------------------------+------------+-------------------------+
| Foreign exchange control      | Money and  | For recurrent           |
|                               | Credit     | operations: licensing   |
|                               | Depart     | delegated to commercial |
|                               | ment/BECAO | bank; for capital       |
|                               | (Central   | operations: application |
|                               | Bank of    | form from and           |
|                               | West       | application to Money    |
|                               | African    | and Credit Department   |
|                               | States)    | (MCD).                  |
+-------------------------------+------------+-------------------------+
| Import/Export Card            | Ministry   | Information form,       |
|                               | of Trade   | certificate of          |
|                               | /External  | registration with the   |
|                               | trade      | Trade Register,         |
|                               | Department | certificate of          |
|                               |            | registration with the   |
|                               |            | taxpayer account, two   |
|                               |            | facial-view             |
|                               |            | photographs, notarial   |
|                               |            | statutes, payment of    |
|                               |            | CFAF 60,000 in dues.    |
+-------------------------------+------------+-------------------------+
| Imports/Exports               | Customs    | Customs declaration,    |
|                               |            | invoices (merchandize,  |
|                               |            | fret, etc.), shipping   |
|                               |            | documents, Evidence of  |
|                               |            | verification (as        |
|                               |            | applicable),            |
|                               |            | Certificate of Origin,  |
|                               |            | sale authorizations may |
|                               |            | be required for         |
|                               |            | specific products,      |
|                               |            | foreign exchange        |
|                               |            | documents, customs duty |
|                               |            | exemption certificate   |
|                               |            | (as applicable) .       |
+-------------------------------+------------+-------------------------+
| Customs Duty Exemption        | APIX       | Customs clearance form. |
| Certificate                   |            |                         |
+-------------------------------+------------+-------------------------+
| Domestic Trade                | Domestic   | Sale authorization:     |
|                               | Trade      | sale declaration,       |
|                               | Department | packaged product        |
|                               |            | sample, supplier's      |
|                               |            | invoice, possibly lab   |
|                               |            | testing certificate     |
|                               |            | delivered abroad.       |
+-------------------------------+------------+-------------------------+
| Payment of indirect tax       | Treasury   | Form and attachments.   |
|                               | Department |                         |
+-------------------------------+------------+-------------------------+
| Payment of domestic indirect  | Internal   | Form and attachments    |
| tax                           | Revenue    |                         |
|                               | Service    |                         |
+-------------------------------+------------+-------------------------+
| Workers' Movement Declaration | Labor      | Declaration form,       |
| (WMD)                         | Inspection | employment contract,    |
|                               |            | visa for foreigners.    |
+-------------------------------+------------+-------------------------+
| Tax clearance                 | Internal   | Application form.       |
|                               | Revenue    |                         |
|                               | Service    |                         |
|                               | and        |                         |
|                               | Treasury   |                         |
+-------------------------------+------------+-------------------------+

B. An Assessment of the Plan of Action []{#__RefHeading___Toc8460570
.anchor}

3.  Based on the investor's roadmap, a Plan of Action was drawn up in
    December 1999. The objective was to streamline the procedures in
    force in Senegal. Before considering the Plan of Action and
    identifying recent developments, many points need to be recalled:

-   the initial impulse and development of the Plan of Action were
    placed under the responsibility of the office of the Prime Minister;

-   the measures contained in the final Plan of Action were a compromise
    reached following (technical) consultations with the administrations
    concerned;

-   it was suggested to grade measures with specific deadlines and to
    allocate responsibilities.

    1.  The Plan of Action contains thirty four (34) measures covering
        most of the procedures identified along the investor's roadmap.
        These measures are summarized in Table I-2 hereinafter. In March
        2002, FIAS estimated that about sixteen (16) of them had been
        partly of fully implemented, that is, about 45% of total. It is
        important to point out that almost two-thirds of the adopted
        measures are concentrated under the general and operational
        formalities. The most significant progress was made in company
        registration, licensing under the Investment Code and access to
        free export company status. At the operations level, customs
        formalities and tax clearance were also significantly improved
        by adopting three measures from the Plan of Action.

Table I-2: Plan of Action Follow Up, March 2002

+------------+---+---+--------------------------------------+-----------------+---+
| **AC       | * |   |                                      | ### IMPLEM      |   |
| TIVITIES** | * |   |                                      | ENTATION STATUS |   |
|            | M |   |                                      |                 |   |
|            | e |   |                                      |                 |   |
|            | a |   |                                      |                 |   |
|            | s |   |                                      |                 |   |
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|            | s |   |                                      |                 |   |
|            | * |   |                                      |                 |   |
|            | * |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| GENERAL    |   |   |                                      |                 |   |
| FORMALITES |   |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| ### Gener  | 1 |   |                                      | Not             |   |
| al Remarks | . |   |                                      | implemented.    |   |
|            |   |   |                                      |                 |   |
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+------------+---+---+--------------------------------------+-----------------+---+
| Licensing  | 2 |   |                                      | Implemented by  |   |
| under the  | . |   |                                      | decree          |   |
| Investment |   |   |                                      | n°2000-417      |   |
| Code and   |   |   |                                      | dated June      |   |
| delivery   | s |   |                                      | 14^th^ , 2000.  |   |
| of customs | i |   |                                      |                 |   |
| duty       | m |   |                                      | Implemented by  |   |
| exemption  | p |   |                                      | circular n°     |   |
| ce         | l |   |                                      | 3744 dated June |   |
| rtificates | i |   |                                      | 29^th^ 2000 in  |   |
| as part of | f |   |                                      | force.          |   |
| tax        | y |   |                                      |                 |   |
| i          |   |   |                                      | Not             |   |
| ncentives. |   |   |                                      | implemented.    |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      | Not implemented |   |
|            | l |   |                                      | because         |   |
|            | i |   |                                      | Community Code  |   |
|            | c |   |                                      | not yet adopted |   |
|            | e |   |                                      | by WAEMU.       |   |
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|            | ; |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Licensing  | 6 |   |                                      | Implemented.    |   |
| as a free  | . |   |                                      | Decree 2000-422 |   |
| export     |   |   |                                      | dated June      |   |
| company    |   |   |                                      | 14^th^, 2000.   |   |
|            | S |   |                                      |                 |   |
|            | i |   |                                      | Implemented.    |   |
|            | m |   |                                      |                 |   |
|            | p |   |                                      |                 |   |
|            | l |   |                                      |                 |   |
|            | i |   |                                      |                 |   |
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|            | n |   |                                      |                 |   |
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|            | a |   |                                      |                 |   |
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|            | ; |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Reform of  | 7 |   |                                      | Implemented.    |   |
| d          | . |   |                                      | In              |   |
| eclaratory |   |   |                                      | ter-ministerial |   |
| f          |   |   |                                      | Order February, |   |
| ormalities | I |   |                                      | 2000.           |   |
|            | n |   |                                      |                 |   |
|            | s |   |                                      | Partly          |   |
|            | t |   |                                      | implemented.    |   |
|            | i |   |                                      | Establishment   |   |
|            | t |   |                                      | of APIX.        |   |
|            | u |   |                                      |                 |   |
|            | t |   |                                      | Implemented.    |   |
|            | e |   |                                      | Effective       |   |
|            |   |   |                                      | institution of  |   |
|            |   |   |                                      | a single NINEA  |   |
|            |   |   |                                      | number,         |   |
|            |   |   |                                      | January, 2002.  |   |
|            | a |   |                                      |                 |   |
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|            | ; |   |                                      |                 |   |
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|            | 8 |   |                                      |                 |   |
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|            | n |   |                                      |                 |   |
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|            | p |   |                                      |                 |   |
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|            | a |   |                                      |                 |   |
|            | n |   |                                      |                 |   |
|            | c |   |                                      |                 |   |
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|            |   |   |                                      |                 |   |
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|            | w |   |                                      |                 |   |
|            | i |   |                                      |                 |   |
|            | t |   |                                      |                 |   |
|            | h |   |                                      |                 |   |
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|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            | O |   |                                      |                 |   |
|            | H |   |                                      |                 |   |
|            | A |   |                                      |                 |   |
|            | D |   |                                      |                 |   |
|            | A |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            | r |   |                                      |                 |   |
|            | u |   |                                      |                 |   |
|            | l |   |                                      |                 |   |
|            | e |   |                                      |                 |   |
|            | s |   |                                      |                 |   |
|            | ; |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Delivery   | 1 |   |                                      | Not             |   |
| of         | 0 |   |                                      | implemented.    |   |
| foreigner  | . |   |                                      |                 |   |
| ID card    |   |   |                                      |                 |   |
|            | r |   |                                      |                 |   |
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|            | n |   |                                      |                 |   |
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|            | D |   |                                      |                 |   |
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|            | d |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
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|            |   |   |                                      |                 |   |
|            | t |   |                                      |                 |   |
|            | o |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
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|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            | t |   |                                      |                 |   |
|            | h |   |                                      |                 |   |
|            | r |   |                                      |                 |   |
|            | e |   |                                      |                 |   |
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|            | m |   |                                      |                 |   |
|            | o |   |                                      |                 |   |
|            | n |   |                                      |                 |   |
|            | t |   |                                      |                 |   |
|            | h |   |                                      |                 |   |
|            | s |   |                                      |                 |   |
|            | ; |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| S          |   |   |                                      |                 |   |
| PECIALIZED |   |   |                                      |                 |   |
| LICENSING  |   |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Hotel,     |   | 1 |                                      | Implemented.    |   |
| travel     |   | 1 |                                      | Authorization   |   |
| agency and |   | . |                                      | dropped under   |   |
| tourist    |   |   |                                      | decree 2000-417 |   |
| transports |   | D |                                      | dated June      |   |
| projects   |   | r |                                      | 14^th^.         |   |
|            |   | o |                                      |                 |   |
|            |   | p |                                      | Not             |   |
|            |   |   |                                      | implemented.    |   |
|            |   |   |                                      | Draft decrees   |   |
|            |   |   |                                      | finalized by    |   |
|            |   |   |                                      | Committee since |   |
|            |   | t |                                      | August 2000.    |   |
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|            |   | l |                                      |                 |   |
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|            |   | a |                                      |                 |   |
|            |   | g |                                      |                 |   |
|            |   | e |                                      |                 |   |
|            |   | n |                                      |                 |   |
|            |   | c |                                      |                 |   |
|            |   | y |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   | l |                                      |                 |   |
|            |   | i |                                      |                 |   |
|            |   | c |                                      |                 |   |
|            |   | e |                                      |                 |   |
|            |   | n |                                      |                 |   |
|            |   | s |                                      |                 |   |
|            |   | i |                                      |                 |   |
|            |   | n |                                      |                 |   |
|            |   | g |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   | p |                                      |                 |   |
|            |   | r |                                      |                 |   |
|            |   | o |                                      |                 |   |
|            |   | c |                                      |                 |   |
|            |   | e |                                      |                 |   |
|            |   | d |                                      |                 |   |
|            |   | u |                                      |                 |   |
|            |   | r |                                      |                 |   |
|            |   | e |                                      |                 |   |
|            |   | ; |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Licensing  |   | 1 |                                      | Implemented.    |   |
| for        |   | 3 |                                      | Licensing       |   |
| admission  |   | . |                                      | application     |   |
| to Dakar   |   |   |                                      | form for        |   |
| Technopole |   | M |                                      | admission to    |   |
|            |   | a |                                      | Technopole      |   |
|            |   | k |                                      | updated and     |   |
|            |   | e |                                      | made consistent |   |
|            |   |   |                                      | with the        |   |
|            |   |   |                                      | provisions of   |   |
|            |   |   |                                      | decree n°       |   |
|            |   |   |                                      | 97-291.         |   |
|            |   | l |                                      | Application     |   |
|            |   | i |                                      | form available  |   |
|            |   | c |                                      | on the Internet |   |
|            |   | e |                                      | since June      |   |
|            |   | n |                                      | 19^th^ , 2000.  |   |
|            |   | s |                                      |                 |   |
|            |   | i |                                      | Implemented .   |   |
|            |   | n |                                      | Same.           |   |
|            |   | g |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   | a |                                      |                 |   |
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|            |   | p |                                      |                 |   |
|            |   | l |                                      |                 |   |
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|            |   | n |                                      |                 |   |
|            |   |   |                                      |                 |   |
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|            |   | m |                                      |                 |   |
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|            |   | n |                                      |                 |   |
|            |   | ° |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   | 9 |                                      |                 |   |
|            |   | 7 |                                      |                 |   |
|            |   | - |                                      |                 |   |
|            |   | 2 |                                      |                 |   |
|            |   | 9 |                                      |                 |   |
|            |   | 1 |                                      |                 |   |
|            |   |   |                                      |                 |   |
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|            |   | l |                                      |                 |   |
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|            |   | ; |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Licensing  |   |   | 15. Reduce total waiting time for    | Not implemented |   |
| fishing    |   |   |     application processing and       |                 |   |
| boats      |   |   |     signing of fishing licenses to a | Not             |   |
|            |   |   |     maximum period of two months.    | implemented.    |   |
|            |   |   |     Failure to respond within this   |                 |   |
|            |   |   |     time frame will mean approval    | Not             |   |
|            |   |   |     and license must be granted;     | implemented.    |   |
|            |   |   |                                      |                 |   |
|            |   |   | 16. Reinforce the mandate of the     |                 |   |
|            |   |   |     Fishing Licensing Committee      |                 |   |
|            |   |   |     along the lines defined in the   |                 |   |
|            |   |   |     Committee's report;              |                 |   |
|            |   |   |                                      |                 |   |
|            |   |   | 17. Don't grant fishing licenses to  |                 |   |
|            |   |   |     boats holding only a provisional |                 |   |
|            |   |   |     Senegalese nationality           |                 |   |
|            |   |   |     certificate;                     |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Mining     |   |   | 18. Reform the Mining Code;          | Not             |   |
| licensing  |   |   |                                      | implemented.    |   |
+------------+---+---+--------------------------------------+-----------------+---+
| ACCESS TO  |   |   |                                      |                 |   |
| LANDS      |   |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Access to  |   | 1 |                                      | Implemented.    |   |
| lands and  |   | 9 |                                      |                 |   |
| property   |   | . |                                      | Not             |   |
| tr         |   |   |                                      | implemented.    |   |
| ansactions |   | S |                                      |                 |   |
|            |   | y |                                      | Not             |   |
|            |   | s |                                      | implemented.    |   |
|            |   | t |                                      |                 |   |
|            |   | e |                                      | Not implemented |   |
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+------------+---+---+--------------------------------------+-----------------+---+
| Delivery   |   | 2 |                                      | Not             |   |
| of         |   | 3 |                                      | implemented.    |   |
| building   |   | . |                                      |                 |   |
| permit     |   |   |                                      | Not             |   |
|            |   | R |                                      | implemented.    |   |
|            |   | e |                                      |                 |   |
|            |   | d |                                      | Not             |   |
|            |   | u |                                      | implemented.    |   |
|            |   | c |                                      |                 |   |
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|            |   |   |                                      |                 |   |
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|            |   | ; |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Delivery   |   | 2 |                                      | Implemented.    |   |
| of         |   | 6 |                                      | Law finalized.  |   |
| no-e       |   | . |                                      |                 |   |
| nvironment |   |   |                                      | Implemented.    |   |
| impact     |   | R |                                      |                 |   |
| permit     |   | e |                                      |                 |   |
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|            |   | s |                                      |                 |   |
|            |   | ; |                                      |                 |   |
|            |   |   |                                      |                 |   |
|            |   | 2 |                                      |                 |   |
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+------------+---+---+--------------------------------------+-----------------+---+
| O          |   |   |                                      |                 |   |
| PERATIONAL |   |   |                                      |                 |   |
| F          |   |   |                                      |                 |   |
| ORMALITIES |   |   |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Simp       |   | 2 |                                      | Implemented.    |   |
| lification |   | 8 |                                      |                 |   |
| of import, |   | . |                                      | Implemented.    |   |
| export and |   |   |                                      |                 |   |
| customs    |   | S |                                      |                 |   |
| clearance  |   | i |                                      |                 |   |
| p          |   | m |                                      |                 |   |
| rocedures, |   | p |                                      |                 |   |
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|            |   | ; |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Delivery   |   | 3 |                                      | Not             |   |
| of         |   | 0 |                                      | implemented.    |   |
| Importe    |   | . |                                      |                 |   |
| r/Exporter |   |   |                                      |                 |   |
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|            |   | ; |                                      |                 |   |
+------------+---+---+--------------------------------------+-----------------+---+
| Delivery   |   | 3 |                                      | Not             |   |
| of         |   | 1 |                                      | implemented..   |   |
| contract   |   | . |                                      |                 |   |
| visas for  |   |   |                                      | Not             |   |
| displaced  |   | I |                                      | implemented\... |   |
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+------------+---+---+--------------------------------------+-----------------+---+
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|  clearance |   | . |                                      | 21^st^, 2000.   |   |
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+------------+---+---+--------------------------------------+-----------------+---+

1.  While these efforts are noteworthy, no or little progress was made
    in the categories relating to access to land, land-use planning and
    sectoral licensing. The lack of progress is highlighted by the
    private sector which believes that the main administrative obstacle
    today in Senegal is linked to the difficulty to connect to basic
    infrastructures (68.1 of companies surveyed responded it is an
    obstacle) followed by the legislation on office or building
    acquisition/renting. A classification of the main administrative
    obstacles as perceived by the private sector is shown in Table I-3
    hereinafter.

2.  It must be explained why the government was slow in implementing
    some parts of the Plan of Action. This not only penalizes investors
    but it is also responsible for the misallocation of the State's
    human and financial resources -- both at the central and local
    levels. However, prior to undertaking this analysis in the next
    chapter, we still want to find out whether the measures adopted
    actually had an impact on the time spent by an investor on the
    administrative roadmap in Senegal. This quantitative exercise will
    help us refine our diagnosis.

Table I-3: Main Administrative Obstacles perceived by the Private Sector

In % of the number of companies surveyed

  ---- ----------------------------------------------------------- -----------
                                                                   Obstacles

  1    Utility connections (water supply, power supply,            68.1%
       communication)                                              

  2    Tax system                                                  65.0%

  3    Legislation on acquisition of offices or buildings          64.4%

  4    Customs procedures                                          64.4%

  5    Company registration (TR, NINEA, IPRES, CSS, Labor          55.6%
       Inspection,...                                              

  6    Activity licensing and regulation                           53.4%

  7    Legislation on social security                              51.3%

  8    Labor rules and regulations                                 51.3%

  9    Bank lending rules and regulations                          51.3%

  10   Import tariff rules and regulations                         49.4%

  11   Health legislation                                          47.5%

  12   Export rules and regulations                                45.5%

  13   Foreign currency/Foreign exchange rules and regulations     41.3%

  14   Standards and quality control certificate                   35.6%

  15   Price control                                               34.4%

  16   Foreign investment rules and regulations                    30.6%

  17   Work permit/Immigration                                     24.4%
  ---- ----------------------------------------------------------- -----------

Source: FIAS and APIX survey (2002)

C. Quantitative Evaluation of Action Impact
[]{#__RefHeading___Toc8460572 .anchor}

3.  The quantitative approach used is to compare the waiting time
    associated with each procedure in Senegal between 1998 and 2002. The
    situation of about twenty African countries will also be compared.

4.  The focus is waiting times rather than direct financial costs, for,
    except for a few formalities, these are relatively not expensive. On
    the other hand, the waiting times induced by administrative red tape
    implies an important opportunity cost for most investors.[^9] To
    determine these waiting times, the method used was primarily to
    interrogate the administrative departments concerned and to compare
    "official waiting times". In a second step, we compare these
    official waiting times with those reported by the 184 companies
    during our survey.

5.  Prior to commenting on the results, it is important to recall the
    advantages and limits of this quantitative approach. Its main
    advantages are that it offers: a) a performance evaluation over
    time; b) a relatively homogenous base for an international
    comparison; c) an evaluation of action impact on the investor's
    roadmap. One must admit, however, that neither the waiting times nor
    the procedures are always homogenous so some generalizations may be
    necessary.

6.  We start with a comparison of official waiting times for three (3)
    of the four (4) main categories of administrative procedures in 1998
    and 2002 in Senegal and in about twenty other African countries
    (Table I-4). The main information gathered from this comparative
    table is that:

-   the total time required to cover the investor's administrative
    roadmap in Senegal increased on average from 495 to 563 working days
    between 1998/1999 and 2002;

-   the significant progress noted in the fulfillment of general and
    operational formalities does not compensate for time extension in
    access to land, site layout and connections to the main basic
    infrastructures;

```{=html}
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```
-   Senegal's performance is lower than the average of 20 other African
    countries in particular because of the difficulty to make a land
    secure. Only Mozambique, Uganda and Tanzania exhibit waiting times
    that are longer than Senegal's in this category.

    1.  The positive aspect of this is that there seems to exist some
        strong positive correlation between the implementation of
        measures recommended in the Plan of Action and the significant
        reduction in some of the waiting times. It took about 15 days
        less in 2002 to complete general formalities than in 1998/1999
        notably as a result of progress made with respect to the Single
        Window (even though we shall see further herein that the Single
        Window procedures could be further simplified). The same
        observation may apply to operational formalities for which it
        takes about 11 days less to complete. These two categories also
        witnessed most of the progress in the implementation of the Plan
        of Action. On the other hand, the difficulties encountered in
        streamlining land access procedures translated into a
        substantial increase in waiting times.

    2.  A closer examination of the waiting time associated with each
        procedure reveals that the longest waiting times are induced: by
        access to (national property) land, site layout, obtaining
        building permits, connection to water supply and drainage,
        Single Window and labor inspection. It may easily take more than
        six months to obtain a foreigner identity card but a provisional
        authorization may be obtained within about twenty days which is
        the waiting time reported in Table I-4 hereinafter.

        Table I-4: Comparison of official waiting times associated with
        administrative procedures in Africa -- Number of days a/,b/

<table>
<colgroup>
<col style="width: 12%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 0%" />
<col style="width: 3%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 6%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
<col style="width: 4%" />
</colgroup>
<tbody>
<tr class="odd">
<td></td>
<td>Senegal 1998-99</td>
<td>Senegal 2002</td>
<td colspan="2">Burkina Faso</td>
<td>Ghana</td>
<td>Kenya</td>
<td>Lesotho</td>
<td>Madagascar</td>
<td>Malawi</td>
<td>Mali</td>
<td>Mauritania</td>
<td>Morocco</td>
<td>Mozambique</td>
<td>Nigeria</td>
<td>South Africa</td>
<td>Swaziland</td>
<td>Tanzania</td>
<td>Tunisia</td>
<td>Uganda</td>
<td>Zambia</td>
<td>Zimbabwe</td>
<td>Average</td>
</tr>
<tr class="even">
<td>General Formalities</td>
<td>82</td>
<td>67</td>
<td></td>
<td>29</td>
<td>34</td>
<td>51</td>
<td>61</td>
<td>171</td>
<td>46</td>
<td>79</td>
<td>54</td>
<td>91</td>
<td>106</td>
<td>18</td>
<td>23</td>
<td>53</td>
<td>71</td>
<td>39</td>
<td>69</td>
<td>29</td>
<td>85</td>
<td>63</td>
</tr>
<tr class="odd">
<td><p>Access to lands &amp; Site</p>
<p>layout c/</p></td>
<td>354</td>
<td>467</td>
<td></td>
<td></td>
<td>255</td>
<td>70</td>
<td>341</td>
<td>375</td>
<td>413</td>
<td>170</td>
<td></td>
<td>278</td>
<td>625</td>
<td>210</td>
<td></td>
<td>117</td>
<td>795</td>
<td></td>
<td>495</td>
<td></td>
<td>90</td>
<td>235</td>
</tr>
<tr class="even">
<td>Operational Formalities</td>
<td>49</td>
<td>29</td>
<td></td>
<td></td>
<td>30</td>
<td>39</td>
<td>122</td>
<td>8</td>
<td>20</td>
<td></td>
<td></td>
<td>63</td>
<td></td>
<td>30</td>
<td></td>
<td>20</td>
<td>45</td>
<td></td>
<td>70</td>
<td></td>
<td>30</td>
<td>27</td>
</tr>
<tr class="odd">
<td>TOTAL d/</td>
<td>495</td>
<td>563</td>
<td></td>
<td></td>
<td>319</td>
<td>160</td>
<td>524</td>
<td>554</td>
<td>479</td>
<td></td>
<td></td>
<td>432</td>
<td></td>
<td>258</td>
<td></td>
<td>190</td>
<td>1027</td>
<td></td>
<td>634</td>
<td></td>
<td>205</td>
<td>429</td>
</tr>
</tbody>
</table>

Source : Morisset and Lumenganeso (2002).

Note :

a/ Because of the specific character of sectoral licensing, an
international comparison is not produced for this category.

b/ Waiting times imply that procedures follow in a row and reflect the
views of the administrative departments concerned..

c/ Implies access to land belonging to the State.

d/ Includes only countries providing information on the three
categories.

3.  The waiting times associated with access to land deserve special
    attention. Obviously, they are too long and frustrating for private
    investors. It is, important, however, to note that procedures may be
    expedited if the investor can acquire a privately-owned land
    forty (40) days or a land pertaining to the industrial zones. It is
    therefore not surprising to see an increase in applications for
    these alternative mechanisms (There are about 400 companies now on
    the waiting list of SODIDA's second industrial zone).

4.  The comparison between official waiting times and those reported by
    the private sector reveals marked differences in some areas, notably
    with respect to the Single Window, labor inspection, obtaining
    customs duty exemption (under the Investment Code regime) and site
    layout. Perhaps, these differences reflect divergences in views and
    lack of transparency within some of the departments, but it may also
    be that the survey did not fully capture recent improvements, for
    instance, at the levels of the Single Window and delivery of customs
    duty exemption. In the latter case, this seems to be more of a
    communication problem on the part of the departments concerned in
    which case they need to better disseminate their recent performance.

    Table I-5: Investor's Roadmap: Estimate in Number of Days a/

+---------------------------------------+-----------+------------------+
|                                       | Waiting   |                  |
|                                       | Time      |                  |
|                                       | (Number   |                  |
|                                       | of        |                  |
|                                       | Working   |                  |
|                                       | Days)     |                  |
+---------------------------------------+-----------+------------------+
|                                       | Official  | Private Sector   |
|                                       | Waiting   | Survey           |
|                                       | Time      |                  |
|                                       |           | Average          |
+---------------------------------------+-----------+------------------+
| GENERAL FORMALITIES                   | 67.0      | 148.2            |
+---------------------------------------+-----------+------------------+
| Single Window                         | 14        | 43.5             |
+---------------------------------------+-----------+------------------+
| Commercial Court                      | 10        | 12.0             |
+---------------------------------------+-----------+------------------+
| Registration (NINEA) b/               | 3         | 19.6             |
+---------------------------------------+-----------+------------------+
| CSS (Social Security Fund)            | 7         | 9.0              |
+---------------------------------------+-----------+------------------+
| IPRES (Provident Fund)                | 7         | 9.4              |
+---------------------------------------+-----------+------------------+
| Labor Inspection                      | 6         | 34.6             |
+---------------------------------------+-----------+------------------+
| Foreigner ID Card c/                  | 20        | 20.0             |
+---------------------------------------+-----------+------------------+
| Registration Foreign Investment       | 1         | n/a              |
+---------------------------------------+-----------+------------------+
| SPECIALIZED LICENSING                 |           |                  |
+---------------------------------------+-----------+------------------+
| Mining                                | 220       | n/a              |
+---------------------------------------+-----------+------------------+
| Tourism                               | n/a       | n/a              |
+---------------------------------------+-----------+------------------+
| Insurance company/ Bank               | 80        | n/a              |
+---------------------------------------+-----------+------------------+
| Industry                              | 4         | n/a              |
+---------------------------------------+-----------+------------------+
| Technology                            | 10        | n/a              |
+---------------------------------------+-----------+------------------+
| Fishery                               | 25        | n/a              |
+---------------------------------------+-----------+------------------+
| Leather Goods                         | 6         | n/a              |
+---------------------------------------+-----------+------------------+
| Arts and Crafts                       | 80        | n/a              |
+---------------------------------------+-----------+------------------+
| ACCESS TO LANDS & SITE LAYOUT d/      | 467.0     | 628.5            |
+---------------------------------------+-----------+------------------+
| State-owned Land                      | 300       | 300.8            |
+---------------------------------------+-----------+------------------+
| Privately-owned Land                  | 40        | n/a              |
+---------------------------------------+-----------+------------------+
| SODIDA                                | n/a       | n/a              |
+---------------------------------------+-----------+------------------+
| Free Industrial Zone                  | n/a       | n/a              |
+---------------------------------------+-----------+------------------+
| Site Layout                           | 90        | 204.2            |
+---------------------------------------+-----------+------------------+
| Environment                           | 15        | n/a              |
+---------------------------------------+-----------+------------------+
| Power Supply (SENELEC)                | 15        | 25.4             |
+---------------------------------------+-----------+------------------+
| Telecommunications (SONATEL)          | 7         | 21.1             |
+---------------------------------------+-----------+------------------+
| Water Supply and Drainage             | 40        | 58.1             |
+---------------------------------------+-----------+------------------+
| Post Office                           | n/a       | 19.2             |
+---------------------------------------+-----------+------------------+
| OPERATIONAL FORMALITIES               | 29.0      | 57.5             |
+---------------------------------------+-----------+------------------+
| Foreign Exchange Control              | 6         | n/a              |
+---------------------------------------+-----------+------------------+
| Importer/Exporter Card                | 1         | n/a              |
+---------------------------------------+-----------+------------------+
| Imports/Exports e/                    | 4         | 5.2              |
+---------------------------------------+-----------+------------------+
| Customs Duty Exemption                | 3         | 28.5             |
+---------------------------------------+-----------+------------------+
| Domestic Trade                        | 6         | 3.7              |
+---------------------------------------+-----------+------------------+
| Labor Regulation                      | 6         | 1.2              |
+---------------------------------------+-----------+------------------+
| Tax Inspection Service f/             | 3         | 18.9             |
+---------------------------------------+-----------+------------------+
| TOTAL g/                              | 563.0     | 834.2            |
+---------------------------------------+-----------+------------------+

> n/a = not available
>
> Notes :
>
> a/ Waiting times imply that procedures follow in a row and reflect the
> views of the administrative services concerned and those of the
> companies surveyed as listed in the first and second columns
> respectively.
>
> b/ Joint tax and statistical registration.
>
> c/Waiting time associated with provisional attestation. The survey
> outcome reveals that average waiting time is 145 days for ID card
> delivery.
>
> d/ Implies that land is acquired from the national property.
>
> e/Exports waiting time.
>
> f/Estimated time to complete tax obligations annually.
>
> g/ Implies that procedures follow in a row, that the investor acquires
> a land from public property and that he/she needs no sectoral
> licensing.

5.  Reported waiting times reflect an average. In fact, formality
    fulfillment varies markedly depending on investor's identity,
    project type and location etc. The survey outcome enables us to
    quantitatively assess this variability of some of the administrative
    procedures. Thus, while the average waiting time under the Single
    Window is 44 days, it varies from 1 to 605 days for about 30% of
    companies reporting a waiting time of less than 14 days (which is
    the one reported by the Authorities). Similar variability is noted
    regarding registration with the commercial court (from 1 to 120
    days), the Internal Revenue Service (from 1 to 60 days) and of
    course, access to land (registration with the land registry may take
    from less than 10 days to more than three months).

6.  It is logical that in an administrative system in which it may take
    almost two years to settle down in Senegal, investors try to
    expedite completion of this procedure, leading to differential
    treatment. In particular, procedures can be accelerated if the
    investor is "coached" by advisers who are familiar with the system.
    Under such circumstances, professions like chartered accountants and
    notaries assume a further dimension, for beyond their sheer
    technical knowledge, they bring along a knot of relations with the
    administration. However, such a system has some weaknesses. First,
    it discriminates against Small and Medium-sized Enterprises (SME),
    which cannot afford the service of these advisers. Secondly, it
    contributes to increasing the cost of the investor's roadmap as the
    cost of hiring advisers is proportionate to roadmap complexity.
    Lastly, even where advisers are useful, they cannot guarantee that
    all procedures will be accelerated and completed within an
    "acceptable" period of time or be competitive at the international
    level.

CHAPTER II[]{#__RefHeading___Toc8460575 .anchor}

AN EXPLANATION OF RECENT DEVELOPMENTS

7.  Administrative procedures remain an obstacle to investment in
    Senegal. Despite the progress made since the adoption of the Plan of
    Action in late 1999 as almost half of the measures have now been
    implemented, it is likely that today the investor's roadmap takes a
    longer time to cover than before for lack of action in many
    categories of administrative obstacles. The Authorities have not
    resolved the main administrative obstacles such as access to land
    and site layout.

8.  This chapter will look into the reasons explaining why some of the
    reforms were slow. The reasons are many and it is not easy to grasp
    them; they have varying intensity according to the type of
    procedures. For the purpose of clarity, however, the following
    reasons will be successively developed:

-   weakness of the institutional framework;

-   lack of performance criteria;

-   slow progress linked to structure development and characteristics of
    the Senegalese economy;

-   inaccuracy of initial diagnosis.

    1.  Looking at these reasons will facilitate our understanding of
        both the administrative procedures and the more general context
        in which reforms are to take place in Senegal. This will lead to
        a series of recommendations that will be presented and discussed
        in the next chapter.

A. A Weak and Changing Institutional Framework
[]{#__RefHeading___Toc8460576 .anchor}

2.  The institutional framework surrounding the Plan of Action follow up
    appeared to be weak because of lack of political support and kept
    changing over the past four years. Beyond the problem of
    administrative formalities and their streamlining, this weakness was
    certainly exacerbated by the political and institutional changes
    that took place with a power change in April, 1999. These changes
    are logical and usually accompany the installation of any new
    government.

3.  In this context, it is important to recall briefly that the
    development and follow up of the Plan of Action was initially placed
    under the responsibility of the Prime Minister's Office. An adviser
    was in charge of the program and was directly making his
    recommendations to the Prime Minister. This adviser also headed a
    commission bringing together all the technical departments directly
    concerned by the measures contained in the Plan of Action. This
    commission held regular meetings about once a month.

4.  Later, by mid-1999, the responsibility for program follow up was
    transferred to the Minister of Economy and Finance. Technically, the
    program was monitored by the Economic Policy Unit (EPU) which
    chaired the work of the Technical Commission. The Technical
    Commission continued holding meetings though irregularly over time.
    The last meeting was reportedly held in July 2001. Lastly, since the
    2001 summer, APIX has taken over responsibility for program follow
    up. The change in responsibility can be explained by the nature of
    the mandate conferred on this agency by decree n°200-562, dated July
    10^th^, 2000.

5.  This brief history illustrates how weak the institutional framework
    that accompanied the Plan of Action was. It demonstrates that the
    Plan of Action did not benefit from a single and permanent
    "champion" over time. The relative instability of the institutional
    framework can explain why nobody was willing to assume
    responsibility for having the Plan of Action implemented as each
    institution blamed sluggish reforms on either its predecessor or
    successor. Besides, because of these repeated changes, the technical
    knowledge of the Plan of Action was scattered within the
    administration.

6.  Lack of institutional stability also reflects the non-participation
    of the private sector in the program. Its involvement could have
    ensured some degree of continuity in program follow up in the course
    of time. This participation turned out to be an essential stability
    factor in countries like Venezuela or Colombia which are
    nevertheless more subject to political instability than Senegal. It
    is important to point out that the participation of the private
    sector should not be at the decision-making level because this
    remains the prerogative of the State. There is clearly a conflict of
    interest if the private sector decides about the relevance of some
    of the administrative formalities. On the other hand, the private
    sector's view on action outcome should constitute an essential
    barometer of reform follow up that should help assess their real
    impact.

7.  This brief description underscores the importance of the
    institutional framework for an adequate follow up of the Plan of
    Action. In fact, it is essential that this framework ensure: a) a
    good representation of the administrations so that actions which are
    often transversal in nature could be coordinated since they imply
    the participation of many ministries or agencies; b) support by the
    highest political authorities, which contributes to ensuring program
    visibility and continuity over time, and c) an active participation
    of the private sector not so much in decision-making but rather as a
    barometer to assess the real impact of reforms and to maintain the
    priorities. The recommendations that will be made in the next
    chapter will aim at ensuring that such conditions are met in
    Senegal.

> B. Lack of Performance Criteria[]{#__RefHeading___Toc8460577 .anchor}

8.  The Plan of Action adopted in December 1999 focused on measures that
    needed to be taken at the administrative or legislative level to
    streamline existing formalities. Emphasis was laid on the actions
    called for and not on the results expected along the investor's
    roadmap. In other words, the Plan of Action did not contain any
    performance criteria designed to capture measures' impact on the
    waiting time and financial costs associated with the formalities
    that companies must go through in Senegal.

9.  This lack of performance criteria had some consequences on reform
    follow up for at least three reasons:

-   adopting measures does not necessarily ensure their having a real
    impact on the investor's roadmap. Often, changes in legislative
    texts are not reflected in real life due to the practices of both
    administrations and companies. FIAS noted that it was difficult for
    the technicians in charge of the program within the government to
    assess the real progress made;

-   in the final analysis, results determine the efficiency and success
    of proposed measures. It is useful to streamline procedures because
    this allows an effective reduction of costs for the investor (in
    terms of time and financial costs) and thus facilitates investments.
    A reduction of the waiting times associated with some of the
    formalities also helps allocate more efficiently the State's
    resources;

-   the follow up of proposed measures would have been facilitated by
    the adoption of quantitative performance criteria. For example, a
    gradual reduction of waiting times over time or a comparison with
    the performance of other countries might have further motivated the
    administrative departments concerned and, possibly, sensitized
    politicians to the implementation of the Plan of Action.

    1.  FIAS believes the establishment of performance criteria to be so
        important that it will be a central element in the
        recommendations that will be discussed at length in the next
        chapter.

C.  Taking into consideration the General Context of the Senegalese
    Economy

    1.  Streamlining investment-related administrative formalities
        requires a series of bureaucratic and administrative
        simplifications. Very often, problems are traced to redundant
        and unnecessarily complex procedures. Under such circumstances,
        the remedies are relatively simple to the extent that they
        require an administrative change that is relatively easy to put
        in place. This was the logic guiding most of the actions
        recommended in the Plan of Action.

    2.  Whereas, this was an optimistic logic which ignored a number of
        hindrances existing in the Senegalese reality. Some of these
        hindrances have been temporarily prompted by specific events or
        delays in the adoption of a new Investment Code at the regional
        level, others are more of a structural nature and are more
        deeply rooted in the country's reality.

    3.  In this context, it appeared that the Plan of Action
        under-estimated the sluggishness of legislative changes in
        Senegal even though, technically speaking, they have been
        accepted by the government. Thus, many measures have been
        delayed due to sluggish legislative actions within the
        Government and Parliament. The measures relating to the
        Investment Code and Mining Code are part of these delayed
        measures. While technically speaking, there seemed to be an
        agreement on the adoption of the measures contained in the Plan
        of Action, these remained dependent on the passing of
        corresponding laws. In the case of the Investment Code, inertia
        combined with the lack of coordination at the sub-regional
        level, for this is a community code.

    4.  Many measures also called for economic policy global reforms for
        which a technical or political consensus could not be reached.

-   The actions recommended to facilitate connections to the main
    infrastructures were strongly influenced by the privatization policy
    followed by the government. For instance, the success of the
    telecommunications sector explains the shortening of connection
    waiting time while problems in the power sector are responsible for
    current waiting times. These problems go beyond the administrative
    framework of the Plan of Action.

-   Actions relating to access to land depend on the land and
    decentralization policies pursued by the State. The increased power
    assumed by local authorities in land-use planning often explains the
    extension of waiting times because they lack the technical capacity
    and duplicate work with the central administration.

-   Delays by the taxation authorities are linked to the complexity of
    the tax system currently in force in Senegal. Tax multiplicity,
    difficulty in defining a tax base for certain tax deductions, lack
    of coordination among the departments both at the collection and
    control levels are responsible for the problems confronting the
    taxation authorities[^10].

    1.  Inversely, customs success was certainly stimulated by customs
        reform within ECOWAS and by the implementation of WTO agreement.
        Tariff streamlining and harmonization of some of the procedures
        are behind the shortening of the customs clearance waiting time
        observed over the past few years (explanation of customs success
        can be found in Box III-5 presented in the next chapter).

    2.  The only fact that economic policies were ignored cannot explain
        delays in the streamlining of administrative procedures; the
        fact that some of the measures adopted did not produce the
        expected enhancing impact on the investment environment is also
        to be blamed. For instance, while the Single Window succeeded in
        reducing licensing waiting time under the Investment Code, one
        may query the relevance of the customs duty exemptions granted
        under this licensing[^11]. In other words, it could be argued
        that administrative streamlining with respect to the Single
        Window did but facilitate the establishment of a formality which
        contributes to negatively affecting resource allocation in
        Senegal. This argument will be particularly highlighted when we
        examine the resources used by the Single Window and the customs
        administration (See Box II-1 hereinafter).

    3.  Last and not least, an administrative reform often requires a
        change in the mentality of civil servants and at times of system
        users. The experiences of many countries and recent economic
        literature have demonstrated indeed that the complexity of
        administrative formalities is often there to facilitate illicit
        behaviors both in the public and private sectors. Embezzlement
        opportunities increase in a complicated and non-transparent
        system[^12].

    4.  Many recent empirical studies have demonstrated that the
        streamlining of administrative barriers is made easier in an
        environment characterized by: a) enhanced governance or less
        corruption in government; b) greater opening of the economy to
        foreign countries; and c) adequate salaries for civil
        servants[^13]. For example, Chart II-1 hereinafter, shows that
        African countries with a good governance enjoy lower
        administrative costs. Senegal is about mid-way compared to other
        countries.

Chart II-1 : Correlation between State Governance and Administrative
Costs

> ![](media/image3.wmf)Source : Morisset and Lumenganeso (2002).

5.  Under these circumstances, it seems that the success of the reforms
    designed to streamline the investor's roadmap in Senegal is closely
    linked to the Government's capacity to reduce the level of
    corruption and enhance State governance. The streamlining of
    administrative procedures should be part and parcel of the civil
    service reform including the revision of civil servants' salaries.

D. An Incomplete Diagnosis []{#__RefHeading___Toc8460580 .anchor}

6.  The establishment of a Plan of Action was hindered by the changing
    nature of the institutional framework, the lack of effective
    performance criteria and many other obstacles traced to the more
    fundamental problems of the Senegalese economy. These constraints
    have already been discussed in the previous sections of this
    chapter.

7.  The limited progress made in the implementation of the Plan of
    Action can also be explained by the inaccuracy of some of the
    decisions recommended. This weakness is particularly felt in the
    category of procedures linked to access to land and site layout.
    This is important because it is the category that witnessed the
    least progress in the past four years.

8.  It can be seen from the recommendations on this category contained
    in the Plan of Action that they simply aim at reducing waiting times
    without detailing how such a result could be achieved nor setting
    any objective or performance criteria[^14]. For example, Measure 21
    of the Plan of Action (See Table 1-2) simply stipulates that "The
    registration procedures for national property lands should be
    reformed upstream and deeds should be approved within significantly
    reduced waiting times". This measure is important in view of the
    delays caused by these formalities which may amount to years for
    some investors. Unfortunately, the Plan of Action was not elaborate
    and gave no indication. As in most cases "the enemy is the details"
    and it is necessary to give such details for concrete and
    identifiable actions over time .

9.  FIAS' recommendations in the next chapter will mainly focus on
    improving on the initial diagnosis by identifying new and detailed
    measures.

CHAPTER III[]{#__RefHeading___Toc8460581 .anchor}

RECOMMENDATIONS

10. The success of administrative reform streamlining is mixed. On the
    one hand, significant progress was made in terms of entry
    formalities and especially customs procedures; on the other, the
    situation of sectoral licensing and land access and land-use
    planning procedures remained unchanged or even worsened.

11. As we have seen, there are many reasons to explain this mixed
    result. These include a weak institutional framework, lack of
    performance criteria, basic hindrances in the operation of the
    Senegalese economy and structures and inaccuracy of the initial
    diagnosis. These reasons need to be taken into consideration and
    constitute the main focus of this chapter.

12. FIAS develops two types of recommendations aimed at reinforcing the
    streamlining of administrative procedures in Senegal so as to
    facilitate private investment. The first one will focus on
    *improving* the Plan of Action *per se* by providing a series of
    advices on how best to improve the procedures with a special focus
    on access to land and site layout. It is important to note that
    these recommendations are based on the situation observed by FIAS
    during its stay in March 2002. By definition, the streamlining
    effort should be dynamic and adapted to new circumstances as
    political, institutional, legal and economic policy changes take
    place.

13. This is why the second type of recommendations will focus on the
    *process* through which the implementation of the Plan of Action
    could be facilitated. Emphasis will be successively placed on: a)
    the institutional framework; b) the development of performance
    criteria; and c) an incentive system. The reform process should be
    both targeted and flexible.

14. Lastly, based on these recommendations, an assessment of the needs
    and financial costs associated with the implementation of the Plan
    of Action will be made at the end of this chapter.

15. It is important to mention that FIAS' recommendations should be
    perceived as one element in the Government's reform process. In this
    regard, it was decided that a workshop should be organized to
    discuss the findings of this report. This exercise is a crucial one
    as it will make it possible to assess the level of commitment and
    responsibility both of the private and public sectors and to raise
    awareness among the main economic and political actors of the need
    to reinforce the reform process initiated four years ago.

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A.  Enhancing the Plan of Action[]{#__RefHeading___Toc8460582 .anchor}

    1.  The departing point is of course the materialization of the
        Government's political will to streamline administrative
        procedures. This would also help influence the administrations'
        behaviors which are critical to reform success, as indicated
        earlier on.

    2.  The Plan of Action provided for "the adoption of an Investment
        Procedure Facilitation Act the basic objective of which was to
        attempt to establish a clear and complete doctrine on investment
        procedure facilitation". The first recommendation is therefore
        to adopt such a law.

    3.  The Senegalese Authorities might be inspired by the French Law
        n° 2000-321 dated April 12 2000, which requires administrations
        to respond to a user's application within a prescribed time. As
        a rule, the administration must respond within two months to the
        application filed by a user. Failure by the administration to
        respond within this time frame is construed as an implicit
        rejection. The appeal period starts at the end of this 2-month
        period (Article 21).

    4.  The most interesting aspect of this law is that it provides the
        Government the opportunity to enact application decrees, which
        can waive this general rule by instituting implicit response
        deadlines for acceptance (Article 22). It might be proposed that
        the Senegalese Government make automatic acceptance of
        applications after a given period a general rule like what was
        put in place for the Single Window procedures: " should the
        administration remain silent until the end of the 30-day period,
        the applications filed shall be considered accepted"[^15].

**Box III-1: FRANCE's Reference Text on Administration Response Time**

**Articles 21 and 22 of Law n° 2000-321 dated April 12, 2000**

Article 21

Except where an implicit acceptance decision regime is instituted under
the conditions stipulated in Article 22, failure by the administrative
authority to respond to an application beyond a period of two months
shall be construed as a rejection. Where justified by the complexity or
urgency of the procedure, decrees promulgated by the State Council
provide for a different deadline.

Article 22

Failure by an administrative authority to respond to an application
within two months shall be construed as an acceptance in cases provided
for by the decrees of the State Council. This decision may be subject to
the delivery of a certificate by the administrative authority at the
applicant's request. Where justified by the complexity or the urgency of
the procedure, these decrees provide for a different deadline. They
define where necessary measures to inform third parties. However, these
decrees cannot institute an implicit acceptance decision regime when
France's international obligations, public order, freedom protection and
safeguarding of other principles of constitutional value are opposable
to them. Similarly, except in the field of social security, they cannot
institute any implicit acceptance regime for an application of a
financial nature.

5.  While the Government needs to materialize its will, the Plan of
    Action should also be refined. As pointed out in the previous
    chapter, some of the actions need to be updated or even detailed
    while others are just missing.

6.  Table III-1, hereinafter, recaps all FIAS' recommendations. The
    reader will find a brief description of each of the procedures
    identified along the investor's administrative roadmap.

Tableau III-1 : Recap of Main Recommendations

+---------------------------+------------------------------------------+
| **Procedures**            | **Recommendations**                      |
+---------------------------+------------------------------------------+
| **GENERAL FORMALITIES**   |                                          |
+---------------------------+------------------------------------------+
| Licensing under the       | Introduce new Investment Code and        |
| Investment Code           | shorten delivery time in the meantime.   |
+---------------------------+------------------------------------------+
| Company registration      | \(i\) Develop the use of computers       |
|                           | within the commercial court;             |
|                           |                                          |
|                           | \(ii\) Harmonize base with NINEA.        |
+---------------------------+------------------------------------------+
| Taxpayer's Account No.    | Ensure establishment of NINEA.           |
| (NINEA)                   |                                          |
|                           | Harmonize with company registration and  |
|                           | CSS and IPRES.                           |
+---------------------------+------------------------------------------+
| Social Security Fund      | Harmonize with company registration and  |
| (CSS)                     | CSS and IPRES.                           |
+---------------------------+------------------------------------------+
| Provident Fund (IPRES)    | Harmonize with company registration and  |
|                           | CSS and IPRES.                           |
+---------------------------+------------------------------------------+
| Company Opening (CO)      | None.                                    |
+---------------------------+------------------------------------------+
| Foreigner ID Card         | \(i\) Drop the systematic recourse to    |
|                           | morality report. The police record,      |
|                           | which is an integral part of the         |
|                           | application should be enough. It is,     |
|                           | however, always possible to restrict     |
|                           | inquiry to sensitive countries or to     |
|                           | people who would be employed in          |
|                           | sensitive sectors;                       |
|                           |                                          |
|                           | \(ii\) Delegate Minister's signature;    |
|                           |                                          |
|                           | \(iii\) Introduce automatic acceptance   |
|                           | if no reaction beyond 15 days or         |
|                           | introduce an appeal mechanism.           |
+---------------------------+------------------------------------------+
| Investment Registration   | None.                                    |
+---------------------------+------------------------------------------+
| Brand and Patent          | Speed up the procedures (at the regional |
| Registration              | level).                                  |
+---------------------------+------------------------------------------+
| **SPECIALIZED LICENSING** |                                          |
+---------------------------+------------------------------------------+
| Mining                    | Adopt the Mining Code.                   |
+---------------------------+------------------------------------------+
| Tourism                   | Tourist Agencies : i) Simplify the list  |
|                           | of documents to be produced; ii) replace |
|                           | morality report by a certificate of      |
|                           | character.                               |
|                           |                                          |
|                           | Hotels: i) Increase the resources of     |
|                           | inspection staff ; ii) impose strict     |
|                           | deadlines which if exceeded will signify |
|                           | Authorities' tacit agreement; iii)       |
|                           | appoint a staff from the Ministry of     |
|                           | Tourism with the Single Window.          |
+---------------------------+------------------------------------------+
| Insurance company/ Bank   | None.                                    |
+---------------------------+------------------------------------------+
| Industry                  | Drop the attestation issued by the       |
|                           | Industry Department for imports of       |
|                           | non-dutiable inputs.                     |
+---------------------------+------------------------------------------+
| Fishery                   | None.                                    |
+---------------------------+------------------------------------------+
| Leather Goods             | Remove licensing requirements for        |
|                           | tanneries.                               |
+---------------------------+------------------------------------------+
| Arts and Crafts           | Step up diffusion of information on EIG, |
|                           | in particular, in the regions.           |
+---------------------------+------------------------------------------+
| **ACCES TO LANDS AND SITE |                                          |
| LAYOUT**                  |                                          |
+---------------------------+------------------------------------------+
| Acquisition of national   | \(i\) Prepare a bill to reform the 1932  |
| property lands            | Land Decree;                             |
|                           |                                          |
|                           | \(ii\) Delegate signing of land title    |
|                           | which should no longer be the            |
|                           | responsibility of the Chairman;          |
|                           |                                          |
|                           | \(iii\) Impose response deadlines on the |
|                           | departments concerned and put in place   |
|                           | an appeal mechanism if application is    |
|                           | not processed within this prescribed     |
|                           | time;                                    |
|                           |                                          |
|                           | \(iv\) Increase the resources of the     |
|                           | departments concerned, in particular the |
|                           | Land Registry;                           |
|                           |                                          |
|                           | \(v\) Authorize the publication of the   |
|                           | registration decree in a registered      |
|                           | daily and not only in the Official       |
|                           | Journal;                                 |
|                           |                                          |
|                           | \(vi\) Revise the scale of land leases   |
|                           | dating back to 1988;                     |
|                           |                                          |
|                           | \(vii\) Initiate the project on          |
|                           | systematic registration of national      |
|                           | property lands in priority in the urban  |
|                           | areas;                                   |
|                           |                                          |
|                           | \(viii\) Publish a Land Guide.           |
+---------------------------+------------------------------------------+
| Acquisition of            | \(i\) Drop prior authorization by the    |
| privately-owned lands     | Minister of Finance for transactions     |
|                           | worth more than CFAF 10 million or       |
|                           | otherwise raise the ceiling of such      |
|                           | transactions to CFAF 100 million or even |
|                           | CFAF 200 million;                        |
|                           |                                          |
|                           | \(ii\) Delegate Minister's signing       |
|                           | powers;                                  |
|                           |                                          |
|                           | \(iii\) Adjust land cost price           |
|                           | correction ratio to allow for inflation  |
|                           | in calculation of gains;                 |
|                           |                                          |
|                           | \(iv\) Revise taxation levels as they    |
|                           | discourage notably small investors.      |
+---------------------------+------------------------------------------+
| Acquisition of industrial | Speed up development of industrial areas |
| lands in Dakar            | (with private funds)                     |
+---------------------------+------------------------------------------+
| Free Zone                 | Transform the Free Zone into an industry |
|                           | development area without any tax         |
|                           | incentives other than being an export    |
|                           | processing free zone.                    |
+---------------------------+------------------------------------------+
| Technology                | \(i\) Transform Technopole into an       |
|                           | industry development area without any    |
|                           | special tax incentives;                  |
|                           |                                          |
|                           | \(ii\) Revise government technology      |
|                           | development and dissemination policy.    |
+---------------------------+------------------------------------------+
| Site layout               | \(i\) Establish a Single Window in       |
|                           | Mayors' offices;                         |
|                           |                                          |
|                           | \(ii\) Institute response deadlines;     |
|                           |                                          |
|                           | \(iii\) Put in place an appeal mechanism |
|                           | for applications not processed beyond a  |
|                           | given time period.                       |
+---------------------------+------------------------------------------+
| Environment               | \(i\) Prepare and publish accurate       |
|                           | standard references for each sector so   |
|                           | as to guarantee the quality of           |
|                           | environmental assessments according to   |
|                           | objective standards which are known      |
|                           | beforehand to the investor in order to   |
|                           | ensure greater transparency of the       |
|                           | process;                                 |
|                           |                                          |
|                           | \(ii\) Increase the human and financial  |
|                           | resources of the Environment Department  |
|                           | in order to ensure quicker and less      |
|                           | subjective assessment of applications,   |
|                           | namely Class One type applications (30   |
|                           | to 40 annually).                         |
+---------------------------+------------------------------------------+
| Power supply (SENELEC)    | To be developed according to Senelec     |
|                           | liberalization and privatization         |
|                           | strategy.                                |
+---------------------------+------------------------------------------+
| Telecommunications        | The Government should open up market     |
| (SONATEL)                 | completely to competition at the end of  |
|                           | the monopoly enjoyed by Sonatel so as to |
|                           | speed up introduction of cheaper         |
|                           | technology and increase rural coverage   |
|                           | ratio.                                   |
+---------------------------+------------------------------------------+
| Water Supply (SDE/ONAS)   | Harmonize the respective                 |
|                           | responsibilities of SONES and SdE in     |
|                           | carrying out the rehabilitation work on  |
|                           | which the implementation period depends. |
+---------------------------+------------------------------------------+
| Post office               | \(i\) Speed up installation of post      |
|                           | office boxes to accommodate users'       |
|                           | increasing needs;                        |
|                           |                                          |
|                           | \(ii\) Encourage and facilitate the      |
|                           | establishment of private mail delivery   |
|                           | services.                                |
+---------------------------+------------------------------------------+
| **OPERATIONAL             |                                          |
| FORMALITIES**             |                                          |
+---------------------------+------------------------------------------+
| Foreign exchange control  | Cancel or reduce the 0.25 % tax levied   |
|                           | on capital or recurrent operations       |
|                           | outside the currency area.               |
+---------------------------+------------------------------------------+
| Importer/Exporter Card    | Remove or at least make use of card      |
|                           | flexible. The card should no longer be   |
|                           | mandatory.                               |
+---------------------------+------------------------------------------+
| Imports/Exports           | Strengthen progress made since 1998 and  |
|                           | further reduce waiting time for customs  |
|                           | clearing.                                |
|                           |                                          |
|                           | Introduce follow up indicators such as   |
|                           | waiting time for customs clearing        |
|                           | (average and variance), number of        |
|                           | controls per operation etc.              |
+---------------------------+------------------------------------------+
| Customs Duty Exemption    | Drop the customs duty exemption if the   |
|                           | option is to revise the Investment Code. |
|                           | Otherwise, shorten procedures by         |
|                           | delegating signing powers to the customs |
|                           | officer appointed with the Single Window |
|                           | and giving him/her the responsibility to |
|                           | ensure follow up.                        |
+---------------------------+------------------------------------------+
| Tax payments              | Reinforce Big Company Managements.       |
|                           |                                          |
|                           | Make refund of tax rebates more          |
|                           | transparent and faster.                  |
+---------------------------+------------------------------------------+
| Domestic trade            |                                          |
+---------------------------+------------------------------------------+
| Workers' Declaration (WD) | Replace visa requirement for Senegalese  |
|                           | and WAEMU workers with a prior           |
|                           | declaration, in accordance with the      |
|                           | Community regulation subject to          |
|                           | reciprocal treatment.                    |
+---------------------------+------------------------------------------+
| Tax clearance             | Shorten delivery time.                   |
+---------------------------+------------------------------------------+

7.  To make the presentation short, only new recommendations (compared
    to the 1998 report) will be explained in detail in the following
    sections. FIAS tries as far as possible to make reference to best
    international practices in advising the Senegalese Authorities. Yet
    these are ideas meant to trigger reflection and must in many cases
    be adapted to Senegal's real life.

8.  The order of presentation follows the 4 categories of procedures
    forming the investor's administrative roadmap in the country.

> 1\. General Formalities []{#__RefHeading___Toc8460584 .anchor}

##### Licensing under the Investment Code and Free Export Company Status 

9.  Basically, so long as the legislative texts remain unchanged -- in
    particular, the regional Investment Code has not yet been approved
    -- procedures have not changed. However, a number of institutional
    and administrative actions have contributed to significantly
    shortening waiting times. This progress was made under the aegis of
    APIX and include a) incorporation of the Single Window in APIX which
    was previously lodged with the Ministry of Finance; b) form
    shortening (with the removal in particular of the feasibility
    study); and c) appointment of a customs representative with the
    Single Window -- which allows quicker control of capital goods and
    materials likely to benefit from customs duty and VAT exemption.

10. FIAS' first recommendation would be to adopt a new Investment Code
    either at the national or regional level within WAEMU. There are
    many reasons to explain why and those reasons are detailed in FIAS'
    report on taxation which was submitted to the Authorities in
    December 2000.[^16] It is predicated on the fact that an improved
    common law tax system would help do away with exceptional systems,
    notably those contained in the Investment Code. Such a strategy will
    simplify the tax system applicable to companies in Senegal and
    ensure a more efficient allocation of the State's limited resources.
    The cancellation of tariff exemptions for imported goods would make
    it possible to allocate the resources of the Single Window and
    Customs Administration to more effective uses. The Government of
    Tanzania made similar simplification recently.

11. If the option to modify the Investment Code can not be applied in
    the short term, the Single Window will then have to continue
    operation within the current legislative framework. Under such
    circumstances, reforms can only be limited. They will consist
    primarily in an improvement of current procedures which might be
    administered in an even faster way. For instance, the Single Window
    should allow an investor to fill in his/her application form on
    APIX's Website (and not only to print it). A number of
    recommendations are also made further herein to simplify the
    establishment and delivery procedures for customs duty exemption
    (See paragraphs 149-152).

12. A last recommendation is that APIX should no longer be in charge of
    controlling whether the licensed capital goods have actually been
    used by company. This control is the responsibility of the unit
    recently established to "help out" investors. When the latter visits
    companies, it tries at the same time to identify the problems with
    which investors are confronted and to effect the control. Obviously,
    there is a conflicting objective here, for this unit cannot act at
    the same time as company advisor and controller. Il is advised that
    the control function should be conferred on the Taxation Authorities
    and the Customs administration. This transfer of responsibility
    would enable APIX to concentrate more of its resources on company
    assistance and to be responsive to their concerns.

    *Company Registration*

13. Company incorporation formalities have not been modified since
    1998/1999. Following company incorporation with a notary, the
    company is required to register its statutes with the Internal
    Revenue Service then register itself and obtain the conformity
    declaration from the commercial court. These procedures follow the
    principles established by OHADA. They can be rapidly fulfilled if
    the company employs the service of a notary, about two days, but
    they may take at times 2 to 3 weeks to complete.

14. The recommendations we make is to speed up the registration process
    by ensuring that waiting time is reduced to acceptable standards.
    Setting objectives in terms of the time required to complete
    procedures would be greatly useful. Such objectives might be revised
    gradually until they correspond to best international practices. For
    this approach to be effective, it is important to verify the results
    in the course of time both by the officials running the service and
    private sector users and that they be regularly published so that
    one can measure the progress achieved.

15. For this commitment to be complied with (and as a counterpart), it
    is advised to pursue computerization of the commercial court. In the
    computerization process, it is important to consider integration of
    company registration and tax registration number since both are
    based on similar formalities and require similar information from
    companies. This consolidation was made by many countries (See Box
    III-2 hereinafter) and should be the ultimate objective of Senegal.
    This would also fall in line with the logic behind the single number
    and form which has been recently systematized with the introduction
    of the NINEA.

**Box III-2: The Use of Information Systems in Company Registration**

The French System is based on *Formality Centers* and allows companies
to register at a single location with a single number and form. Inspired
by the French system, the Government of Portugal established the *Centro
de Formalidades das Empresas*, (CFC Network). This system is available
in the seven regional offices that have replaced the six different
visits that companies had to make and reduced waiting time from 4-6
months to 2-3 weeks.

In Italy, the company registration office provides information on all
procedures. Part of this information is compiled beforehand in local
courts. This central point is useful for both companies and the
administration..

The Danish Authorities have developed a data processing system allowing
investors to have access to all required information on a single Web
page. Forms are made available and payments can thus be made directly
without having to go physically to the relevant offices. The United
kingdom has established as a test service on the Web a virtual single
window called "Direct Access Government". Austria, Germany, Greece,
Spain, Ireland, Swede and Belgium have also established an electronic
center based on a similar system.

The Government of Canada has put in place an efficient system with which
companies can register and obtain at the same time a tax registration
number. All forms can be obtained electronically and payments made by
credit card. On returning the documents, the registration certificate is
also obtained electronically within hours. For the tax registration
number, a separate form must be filled and submitted to the Taxation
Authorities (the Canada Customs and Revenue Agency (CCRA)). Registration
is done immediately and the written confirmation and registration number
are received in less than a week..

16. Even though it may be unrealistic to virtually inter-connect all the
    departments concerned through a data processing network, at any rate
    not in the short term, the harmonization of company registration and
    tax registration number might already be started. Eventually,
    technological advancement will make it possible to introduce a
    system in which information flow channels will be shared among
    organisms as is the case in other countries.

##### Tax and Statistical Registration 

17. Since January 2000, tax and statistical registration has been
    standardized as the result of the application of April 5^th^ 1995
    Decree. In principle, a company only needs a single form and a
    single number and a visit to the branch office of the Internal
    Revenue and State Property Head Office (DGID) covering its area to
    register. It is important to note that APIX's Single Window plays a
    role as a "facilitator" for licensed companies (only) that want to
    obtain their NINEA.

18. Our short term recommendations are as follows:

-   to speed up the establishment of a single identifier number through
    collaboration among the departments concerned;

-   to extend the responsibility of the Single Window to cover all
    companies and no longer only those licensed under the Investment
    Code as APIX must gradually assume its role as a formality center.

    1.  It would be wise to develop information flow networks in the
        course of time. Such a network might include the commercial
        court as suggested earlier on. It might also include such
        organisms as the Single Window and possibly the Chamber of
        Commerce. This is of course a medium term objective in view of
        the scope of financial and technological resources that such a
        project requires. This is why the first stage would be to
        harmonize registration forms following the example of NINEA.

    2.  In this regard, the Authorities might take advantage of the
        experience acquired during the development of the GAINDE 2000
        system to process and network information on customs clearing of
        goods. This system was developed by Trade Point (and was later
        adopted by the Customs), which has thus acquired some
        country-specific experience in Senegal with administrations
        networking. The needs for pooling or even networking information
        on company registration show some important similarities with
        the GAINDE 2000 project. By the way, Trade Point has already
        been contacted by the Taxation Authorities within the framework
        of the NINEA project.

        *Affiliation to the Social Security Fund (CSS) and to the
        Provident Fund (IPRES)*

    3.  Our recommendation would be to integrate these registrations
        with that of NINEA as part of an effort to standardize the
        registration procedure. This centralization should be made
        possible by the use of a single form, which might, maybe at a
        later stage, as suggested earlier on, lead to a computerized
        networking of the whole procedure along with all the
        administrations concerned (DGI, CSS, Labor Inspection, IPRES and
        possibly the Commercial Court). For instance, there seems not to
        be any major differences between the information required under
        NINEA and the one for registering with CSS and l'IPRES.[^17]
        Eventually, a network that would include all the major agencies
        with which companies must register, might be put in place.

##### 

##### Foreigner ID Card

4.  Significant delays are reported since it seems that the delivery of
    foreigner ID Card may take more than a year. In order to sidestep
    this delay, the administration issues a receipt following the
    submission of a complete application; the validity of such a receipt
    is 6 months and is renewable. The main cause of delay is reported to
    be linked to the need for an investigation led by the Criminal
    Investigation Department.

5.  Though it is a State prerogative to control migration, it is advised
    that the systematic need to undertake a morality report be dropped.
    The police record which is part and parcel of the application should
    be enough in most cases. It is always possible to restrict the need
    for investigation to sensitive countries or to people who will be
    employed in sensitive sectors. The Authorities are also free to
    undertake an *ex post* investigation and subsequently expel
    immigrants who had clearly been in trouble with the law.

6.  Other suggestions include FIAS' proposal a) to delegate the
    Minister's signature; b) to introduce the automatic acceptance
    principle if no response is received beyond a reasonable time period
    say of two months. An option would be to introduce an efficient and
    independent appeal mechanism allowing the applicant to proceed with
    his/her application after expiry of this deadline. APIX's
    involvement might be considered in cases where applications are
    associated with investment projects as was the case in Tanzania and
    Namibia.

7.  Procedures became faster recently in Tanzania because immigration
    formalities were reduced to less than two months' waiting time
    compared to 6 months in 1997. This progress was achieved without
    basic policy changes only by the administration's will to accelerate
    formalities. The involvement of the Investment Promotion Agency
    (TIC) made ongoing efforts more clearly visible and contributed to
    motivating the departments concerned. In Namibia, faster immigration
    procedures were also made possible by the direct and formal
    participation of the promotion agency in the Government
    Decision-making Committee at least for applications related to
    investment projects. Similar participation might be considered for
    APIX perhaps through the appeal system which might thus draw the
    attention of the Authorities to the importance of some of the
    applications.

> 2\. Sectotal Licensing []{#__RefHeading___Toc8460585 .anchor}

##### Tourism

8.  **Tourist Agencies**. The major cause of delay in licensing is
    traced to the need for the Ministry of Interior to undertake a
    morality report. It may take up to six months, and a year in some
    cases, between application transmission by the Ministry of Tourism
    and completion of the morality report. It seems that at times the
    morality investigation does not even take place. As things stand,
    applications were forwarded to the Ministry of Interior more than
    two months ago and no response has been received so far. The major
    obstacle is traced to the very limited resources available to the
    Ministry of Interior to carry out this morality report.

9.  Our recommendations are as follows:

-   to simplify the component parts of the licensing application by
    retaining only the following documents:

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-   a copy of the police record;

-   a certificate of character (in replacement of the morality report);

-   a deposit of CFAF 500.000;

-   an insurance certificate;

-   a registration with the Trade Register.

    -   to drop the morality report requirement or to retain it only for
        special cases, for instance where there are doubts about the
        police record or the certificate of character.

    1.  **Hotels.** Regarding hotels, licensing is no longer subject to
        prior authorization by the Ministry of Tourism; it is done
        directly by APIX. This, however, raises some problems, for the
        authorization to open an hotel is again under the responsibility
        of the Ministry of Tourism which must carry out an onsite
        inspection. As a result, there are frequent tensions because
        tourism inspectors feel they are not bound by the decision taken
        by APIX. In fact, the authorization to open an hotel is always
        granted because the inspection requirement is often sidestepped
        with the interference of the highest authorities or politicians.
        Our main recommendations are as follows:

```{=html}
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```
-   to impose on the Inspection Service strict deadlines which if
    exceeded would mean tacit agreement;

-   to appoint a staff from the Ministry of Tourism with the Single
    Window who would ensure coordination and timely transmission of
    information between these two organisms.

##### Industry

1.  The attestation granting exemption from customs duties and which is
    delivered by the Mining Department has become irrelevant following
    customs reform within WAEMU, except for "industrial" sugar which is
    still exempted from customs duties. Yet, this procedure has been
    maintained for statistical reasons.

2.  Our recommendation is to drop this procedure and to allow the Mining
    Department to have access to the data collected under NINEA
    registration and/or the Single Window. The information gathered at
    these stages should be quite sufficient.

    *Fishery*

3.  The main recommendation made in the 1998 report remains valid: to
    study the possibility of a shift to an efficient piscatorial
    resource management system either through a quota system with
    differential prices per species or through licensing by auction. It
    is recommended to launch a specific study on the feasibility of such
    a shift.

##### Leather Goods

4.  There has not been any official major change in tannery licensing;
    the procedure remains therefore an obligation. It seems that in
    practice, however, licensing is no longer necessary to engage in
    tanning activity.

5.  If this licensing does no longer play any relevant role in the
    current context, it should be clearly cancelled. Furthermore, this
    cancellation should provide an opportunity to reallocate
    administrative resources within the department, which is not
    currently the case since the staff who is officially in charge of
    licensing has been maintained.

##### Arts and Crafts Department

6.  There are two procedures associated with the arts and crafts: the
    establishment of cooperatives and the establishment of Economic
    Interest Grouping (EIG). The former is very much in demand by
    craftsmen/craftswomen because like associations, it is exempted from
    profit tax. On the other hand, cooperative licensing procedure
    appears to be particularly complex and may take several months. EIG
    is a legal innovation introduced in OHADA[^18]. The procedure for
    establishing an EIG is similar to that of a company with the major
    stage being registration with the Trade Register, however, through
    an extremely simplified incorporation procedure. Therefore, it does
    not imply any licensing. The incorporation of an EIG seems, in fact,
    to be very fast; it is a matter of a few days. The fee payable is
    CFAF 6.000.

7.  It is recommended that EIG should be popularized as it appears to be
    an adequate solution to the complexity of cooperative establishment
    procedures. According to the information gathered by the assigned
    team, this legal form is increasingly successful in the arts and
    crafts sector ad can be seen as an efficient tool for gradually
    formalizing informal activities in the arts and crafts sector. An
    information campaign especially in the provinces should be stepped
    up.

> 3\. Access to Lands and Site Layout[]{#__RefHeading___Toc8460586
> .anchor}

*Access to Lands (State Property)*

8.  Access to State property lands has not been improved since FIAS'
    last report in 1999. The investor's roadmap between land
    identification and securing of land title is divided into many
    stages deemed non-transparent by economic operators. It is not
    unusual for an investor to spend two or even several years before
    obtaining a land title for a land pertaining to national property.

9.  In FIAS' last report, the Property Operations Control Commission was
    identified as one major cause of delay in the procedure for
    acquiring State property lands. In fact, the Commission seldom met
    to examine applications. According to the State Property Head
    Office, the Commission met only five times between 1996 and 2000
    bringing the number of applications on the waiting list to 2,323 in
    October 2000. The State Property Head Office to day reports that all
    applications that had been on the waiting list have now been
    processed. The Commission now meets once (and if necessary twice)
    every month and examines a monthly average of 150 applications. The
    improved operation of the Commission comes as a very positive
    development. One must admit, however, that the problems raised by
    access to State property lands go beyond the Commission's
    activities.

10. First of all, staff shortage and limited financial resources are the
    causes of the longest delays with the State Property Departments.
    Nowhere else is the phenomenon as visible as in the operation of the
    Land Registry. As the technical arm of the State Property
    Department, the Land Registry is often involved with land
    registration procedure. Whereas, it does not possess the necessary
    tools to carry out its mandate. For instance, the Land Registry can
    not produce a reliable land map for the most part of the territory;
    keeping of land titles and file management are still done manually;
    it lacks the very basic equipment such as land survey instruments;
    the service is short of technical staff such as land surveyors and
    draughtsmen.

11. Another weakness is the use of outdated registration procedures: the
    land decree governing land publicity has not been updated since
    1932; the land tile always emanates from the highest authority
    within the government; and the formalities look more like a control
    and selective system in the hand of the State than an open economy
    system.

12. Furthermore, following the 1996 decentralization exercise, local
    authorities assumed a dominant role in deciding on the allocation of
    farming lands. This newly assumed role further slowed the
    administrative process because the organization of the
    decision-making bodies such as the Rural Council remains very
    cumbersome. The search for multiple advises (20 to 30 people within
    the Rural Council), unclear opposition rules and the absence of
    established standards for accepting or rejecting applications impose
    a long negotiation period and make the process unpredictable for
    investors.

13. Finally, the procedures that one should follow to acquire a State
    property land have not been clearly spelt out. It is very difficult
    to obtain any information and often, civil servants give different
    information. Investors discover the procedures as their applications
    make their way through the administration. Investors or their
    advisors are often advised to closely follow up their applications
    through the various stages in order to avoid undue delays. The
    system is so opaque that it may lead to discretionary behaviors when
    applications are processed on a case-by-case basis.

14. Notwithstanding the difficulties in obtaining a public property
    land, applications for State property lands remain high in number
    for two reasons; the first reason is that there are very few
    privately-owned or already registered lands; the second reason is
    that State property lands are much cheaper. In fact, the rent of a
    long lease is still set on the basis of the scale in force
    since 1988. When an individual decides to turn his/her lease into a
    definitive land title as permitted by law since 1994, the purchase
    price applicable is set clearly below the market price. The State
    Property Head Office has already initiated procedures designed to
    revise the scale of rents. A new scale planned for release in April
    2002 should align the prices of State property lands with the market
    price.

15. The State Property Department has already proposed many initiatives
    to remedy the State property land access problem. There is no doubt
    today that it is necessary to revise the 1932 Land Decree and to
    think of a land policy which is more adapted to the current needs of
    Senegal.

16. Pending the development of this new legal framework, many
    initiatives are proposed to simplify the formalities and shorten the
    waiting time.

17. Our first recommendation is to simplify some of the land procedures
    which have remained complicated and often irrelevant or even
    remnants of the past. In this context, it is proposed that:

-   granting of land title be simplified notably by appointing an
    officer to sign the final deed instead of demanding a presidential
    decree;

-   the registration decree be published in a daily licensed to make
    official announcements rather than in the Official Journal. This
    change alone can shorten waiting time by at least two months.

-   inquiry time within the Rural Council be reduced by imposing maximum
    deadlines;

-   consultation time with the departments concerned be shortened since
    the latter are represented on the Commission.

    1.  Our second recommendation is to impose reasonable response
        deadlines on the different staff at the expiry of which the
        positive response of the department concerned will be deemed
        granted.

    2.  Our third recommendation is to revise the scale of lands in
        force since 1988, as soon as possible and as planned

    3.  Our fourth recommendation is to provide the various departments
        with the resources they need to discharge their function. It is
        necessary to computerize the Land Registry in order to ensure an
        efficient keeping and management of land titles, to recruit
        technical staff and inspectors and to put at their disposal
        necessary working tools and utility cars to carry them onsite. A
        project on the establishment of a land register for the
        territory should also be supported. A similar project had
        already been successfully undertaken by the Land Registry, with
        the assistance of one of the donors for the city of Ziguinchor.
        If this experiment is conclusive, it should be extended to other
        communities. It is absolutely necessary for the Authorities to
        concentrate on the communities who have shown a clear will to
        participate in this effort.

    4.  In this context, FIAS supports the systematic national property
        land registration project in the urban areas taking duly into
        consideration of course the rights of the local authorities and
        other possible users. The building of an adequate land reserve
        would considerably reduce the time that investors spend on
        identifying lands and launching [land reallocation]{.mark}
        procedure. However, in view of the country's limited lands in
        the urban areas, the State should not limit itself to only
        registering those lands. The Administration is in a position to
        engage in negotiations with the rural communities in order to
        settle the anticipated [reallocation]{.mark} of farming lands
        according to a land-use planning.

    5.  By the way, the State has already embarked successfully on a
        similar task within the framework of an industry development
        zone such as SODIDA II, where 50 hectares of lands have been
        developed in 6 to 8 months. The option to promote industry
        development zones is detailed further herein along with other
        avenues that deserve being explored by the Authorities. Many
        countries (like for example Hong Kong, Singapore and Egypt) sold
        by auction some public property lands with a clear success as
        described in Box III-3 hereinafter.

    6.  Eventually, it is useful to publish a Land Guide on the sale and
        disposal of State property lands. This will make it possible,
        notably to identify in advance the procedures that have to be
        followed and the fees involved. The Guide should also contain a
        recent leasing and sale pricelist of those lands across all
        provinces.

*Access to Privately-owned Lands*

7.  In its last report, FIAS recommended that the prior authorization
    demanded by the Taxation Authorities for land sale operations in
    excess of CFAF 10 million among individuals should be dropped.
    Though this recommendation was reiterated in the Plan of Action
    developed by the Government, the requirement is still enforced
    today. Apparently, the desire to control tax evasion is the main
    reason explaining the existence of such a measure. The Minister of
    Finance is not convinced that the information gathered by the State
    Property Department while registering the bill of sale is enough for
    that purpose.

8.  Though the cancellation of this measure remains FIAS' primary
    recommendation, failure by the Government to cancel the prior
    authorization of the Ministry of Finance, it might consider raising
    the ceiling of such transactions to CFAF 100 million or even CFAF
    200 million. The decree defining the amount of the transaction dates
    back to 1977 and it is clear today that the value of most of the
    real-estate transactions is higher than this figure. It would be
    relevant for the Minister of Finance to consider delegating
    authorization signing powers so as to reduce waiting time.
    Incidentally, authorizations for transactions of up to CFAF 50
    million have already been signed by the Director General and the
    Director of State Property based on the amounts involved.

9.  The fees involved in the establishment of the bill of sale are many
    and include registration fees and taxes payable to the State. The
    costs associated with the registration of the bill are very high
    (15% of sale price with the possibility of a 5% rebate if the land
    is developed within three years. Though these costs have been
    revised downward (from 20% to 15%), they remain higher than those
    applied in other countries of the region (about 7% in Mali and
    Burkina Faso). The provision for a 5% rebate on new buildings being
    a recent one (less than 3 years), it is too early to be able to
    assess its efficiency. Nevertheless, while the experience of the
    countries of the region in this area is an indication, it turns out
    that it is difficult for investors to obtain that rebate..

10. The determination of the profit tax payable to the State while
    establishing the bill of sale is based on the correction ratios of
    buildings purchase value which have not been updated since 1996
    (February 12^th^ 1998 Decree). The cost price of lands purchased
    since 1996 is therefore not adjusted for inflation. As a result,
    profit is over-estimated at the time of selling these lands. It is
    necessary to regularly update correction ratios of land cost price
    in order to allow for inflation in the calculation of profits.

##### Industrial Zone (SODIDA)

11. It seems that the obstacles identified in the last report of FIAS,
    such as lack of available lands and complex licensing procedure
    followed by the Selection Committee, have been corrected while
    developing the SODIDA II project which is entirely financed with
    private funds (The State provided only the lands). It is provided
    that the licensing procedure should not take more than two working
    days. As the zone is not yet operationalized, it is difficult to say
    whether the 2-day deadline for obtaining licensing will be actually
    respected.

12. In general and in view of the experience of many other countries
    (See Box III-4 hereinafter, the development of industrial zones is
    an efficient way of making lands available to investors in the short
    and medium terms. Though the development of such zones requires huge
    financial and human resources, they offer non-negligible advantages
    because they allow: 1) an easy access to lands and already existing
    industrial infrastructures; 2) control of the industrial development
    of a region so as to preserve natural and cultural heritage as well
    as the environment, and 3) encouragement of industrial
    concentrations, grouping similar industries and allowing the
    development of vertical and horizontal relationship among
    industries.

13. In the prospect of facilitating access to lands and infrastructures,
    the Senegalese Government should accelerate the development of
    industrial zones, notably with the participation of private funding.
    FIAS would like to indicate that it is not necessary to associate
    the development of such industry development zones with tax
    incentives (other than those that already exist). In fact, the main
    advantage of these zones in Senegal would consist in their
    facilitating access to lands and basic infrastructures which remain
    difficult in Senegal.

##### 

##### 

##### Technopole

14. With its 309 hectares of available lands, Technopole represents a
    large land reserve. To date, if you include the Sonatel affiliate
    which had been licensed in 1999, only eight (8) companies have
    qualified for the Technopole Status and three others are on the
    waiting list. Gradually connected to the basic services as companies
    move in, the site clearly faces site layout problems since even the
    Sonatel affiliate is not yet in a position to start its operations
    on the site. According to the head of the Technopole Mission, delays
    in activity launching are due 1) to the lack of a management
    strategy for supervising and controlling activities on the site,
    and 2) to the lack of private funding. So far, the private capital
    is subscribed up to CFAF 100 million and according to the Mission
    head, this amount should be increased tenfold to reach the level of
    financing needed to develop the site. Technopole officials do not
    consider the absence of applications from companies with a major
    research and innovative technology component to be the source of the
    development problems that Technopole is now experiencing.
    Nevertheless, the satisfactory experience with industry development
    zones for which there is excess demand may be compared to that of
    the Technopole.

15. In the prospect of making access to lands easier for a greater
    number of companies, the Government should envisage turning the
    Technopole into an industry development zone. Under such
    circumstances, it would no longer be necessary to provide for tax
    preferences, which should therefore lead to the cancellation of the
    preferential tax regime. This transformation should be made within
    the framework of a revision of the Government's technology
    development strategy.

    *Industrial Free Zone*

16. Since 1999 and at the expiry of the Industrial Free Zone (IFZ) law,
    the lands allocated to the IFZ have been subject to a legal vacuum
    which makes their use and development difficult or even impossible.
    These lands are still managed and leased out by the Free Zone
    Administration which is still waiting for the reinstatement of the
    IFZ law. So far, there are only seven companies located within the
    zone whereas it can accommodate 80 to 100 companies.

17. The IFZ regime should be cancelled and the rules giving access to
    these lands should be clarified so that companies wishing to set up
    business there may easily have access to them following the example
    of the industry development zone strategy. Too many initiatives are
    unwarranted, but it is necessary to "harmonize" approaches to
    developing industry development zones. Furthermore, as in the case
    of long leases, companies that wish so should be allowed to convert
    their leases into a final purchase of the lands after their
    development.

##### Building Permits 

18. Since the last report released by FIAS, significant progress has
    been made including the cancellation of the Sanitation Department's
    advice and the streamlining of application processing by different
    departments. Nevertheless, the situation as a whole did not improve.

19. The search for an external advice outside the State Property
    Department and Land Registry during the processing of applications
    by the Town Planning Department remains the cause of long delays.
    The internal organization of the Town Planning Department is also a
    source of problems. The responsibilities of the Regional Town
    Planning Department and those of the municipality in application
    processing are not clearly demarcated. In fact, while municipalities
    have started developing the necessary technical capacities to
    process applications (as is the case of the Dakar Urban Planning
    Department -- (DAU), the respective roles that each side will play
    in this evaluation is yet to be defined. Today, at least in Dakar,
    the same applications undergo two technical evaluations by the Town
    Planning Department and the Urban Planning Department (DAU).
    Besides, it so happens that these two bodies may diverge on the
    conclusions of application evaluations, which may cause further
    delays for the investor.

20. Municipalities have gradually instituted local taxes to finance
    their activities and these have eventually developed to levels that
    may discourage investments. Some municipalities have for instance
    instituted a 5% plot tax or an additional payment of CFAF 100,000
    for investment projects on their territory. Though the Special
    Delegation of the City of Dakar took measures to remedy this problem
    in the short term (See Appendix B), the level of local taxes remains
    a problem so is their unpredictable character, which heightens the
    risk for investors.

21. One of the ideas that the Government is considering to reduce the
    waiting time associated with the delivery of building permit is to
    establish a single window with the mayor's office which would bring
    together the representatives of all the departments involved in the
    process once a week to examine applications. In this context, the
    mayors' offices would only have a month to sign the authorization;
    beyond that period, the mayor's agreement would be deemed granted.
    The Regional Town Planning Department supports these changes,
    however, some mayors were not very keen on this, arguing that
    decentralization was regressing.

22. Although the project is still being developed with details still to
    be worked out, FIAS supports the principle of a single window for
    building permit applications.

23. Concurrently, APIX suggested that it might be relevant to make a
    distinction between permit applications for large-scale industrial
    and commercial installations and building permit applications for
    private house building. A faster and lighter procedure might be put
    in place for investors. Although this is possible, it is, however,
    likely to complicate the system and to encourage applicants to
    modify their applications *ex ante* so as to meet the criteria
    retained and applied to industrial installations.

24. An alternative would be to institute, like in the British system, an
    appeal mechanism which would be based on the following principle. If
    the building permit application is not processed until past a given
    period of time, say a month, as suggested earlier herein, the
    application is then considered as rejected by the Authorities (this
    is of course an alternative to a proposed automatic application
    acceptance, but this solution is likely to be rejected by the local
    authorities and even by the investors who often need to show an
    official document to prove that their papers are in order). Should
    an application be rejected by the Authorities, the investor will
    have the option to appeal to another Authority. In the case of
    Senegal, it might be proposed that APIX should be an integral part
    of this appeal mechanism. It is advised that the Authorities should
    study this proposal and possibly develop an efficient and fast
    appeal mechanism.

##### Environment 

25. The update on the Environment Code and its Application Decree
    contributed to the solution of the main administrative problems
    which had been identified in the Plan of Action (Publication of the
    Application Decree, exclusive responsibility of the Minister of
    Environment and establishment of a lighter and faster procedure for
    Class Two installations).

26. In order to facilitate the implementation of the new Code, it is
    important to develop and publish reference standards for each sector
    so as to guarantee the quality of environmental evaluations
    according to objective criteria known in advance by the investor.
    These standards should help ensure greater process transparency. It
    is also necessary to increase the human and financial resources of
    the Environment Department if a quicker and less subjective case
    evaluations were to be expected along with an increased capacity to
    carry out regular inspections of Class One plants or companies (30
    to 40 cases annually).

    *Water Supply and Drainage*

27. In Senegal, the urban water supply service which is exploited by the
    *Senegalaise des Eaux* (SDE) through a lease-farming contract, is
    one of the best performing company in Africa[^19]. The coverage rate
    of the urban population is relatively high at an estimated 80% at
    the end of 2000. The result of the consumers' associations polled
    since 2000 reveals a high satisfaction ratio with SdE service, the
    only problem being the average tariffs found too high by industrial
    and commercial consumers.

28. One of the problems affecting the performance of SdE is an obsolete
    network (40 years old on average) that requires a large-scale
    maintenance and rehabilitation program. Yet, assets management is
    retained by the National Water Supply Company (SONES). Disagreement
    in terms of the scope of responsibilities that each party should
    assume in carrying out the rehabilitation work is the cause of
    implementation delays. Our main recommendation is therefore to
    develop definition criteria for levels of network maintenance,
    renewal and rehabilitation such that the responsibilities of SONES
    and SdE are clearly defined in work supervision and implementation.

##### Power Suppply 

29. The sector still has difficulty meeting increasing consumer demand.
    Service quality is strongly affected by an unreliable power supply
    and frequent equipment breakdowns due to their obsolete state.
    Selective power cuts has become systematic in Dakar. The sector
    suffers from chronic under-investment and a management system that
    shows little concern for the client. The much awaited privatization
    of the National Power supply Company, Senelec has still not
    materialized.

30. In Senegal, the problems of the power sector are so deeply rooted
    that they transcend the framework of a study on administrative
    barriers. They require a deep review of the Senelec liberalization
    and privatization process.

##### Telecommunications

31. Well before it was privatized, Sonatel was a public operator with a
    culture close to that of a commercial company geared towards the
    provision of satisfactory service to the clients. Network
    modernization, improved service quality and reduced delays in the
    provision of service have topped the list of the company's
    objectives since 1997. As a result, the number of fixed telephone
    lines was increased by an average 17.5% in the past ten years;
    prices decreased in all market segments while new services such as
    cellular phones, tele-centers and Internet connection were
    developed.

32. Internal surveys revealed a high satisfaction ratio among consumers,
    the main complaint being the very low coverage rate of rural areas
    (657 villages were connected at the end of 2000 compared to 14,500
    surveyed) and difficult access to the Internet. Sonatel is first to
    admit that the coverage rate of the territory and after-sale
    services need to be improved to ensure company inter-connections
    (for instance bank network) and data transmission.

33. the Government should fully open up the market to competition
    immediately after the expiry of Sonatel's monopoly so as to speed up
    the introduction of a cheaper technology, which would also reduce
    rates.

##### Post Office

34. The decision taken by the post office to end home mail delivery in
    February 2002 forced users to seek alternatives such as electronic
    mailing and private mail delivery service. In fact, even if users
    were willing to pay for post office boxes, the post office is in no
    position to meet such a massive demand.

35. Under these circumstances, the previous recommendations of FIAS even
    assume a more urgent character: 1) the post office should make
    significant investments to rapidly meet the growing demand for post
    office boxes; and 2) the installation of international private mail
    delivery service should be encouraged and their operation
    facilitated.

> 4\. Operational Formalities []{#__RefHeading___Toc8460587 .anchor}

##### Foreign Exchange Control

36. The problem identified in FIAS' 1999 report still exists: the
    payment of a 0.25% tax on all transfers (recurrent and capital
    transfers) to countries outside the Franc currency area, which is
    enforced to date. It is recommended that this tax be cancelled.

    *Imports and Exports*

37. FIAS recommends the rapid implementation of the GAINDE 2000 system,
    which should reduce waiting time for customs clearing.

38. While the problem of multiple controls is not as acute as it was in
    1998, nevertheless, it continues being a source of complaint from
    the private sector. For instance, there is evidence that all
    containers are still systematically escorted -- after getting over
    the customs barrier -- up to their final destination where they are
    again checked by the customs. This procedure is totally irrelevant
    and proves that the internal mandates of the different customs
    squads still need to be further clarified -- and that the fight
    against administrative injustice and corruption also needs to be
    improved. FIAS recommends that effort already initiated by the
    customs should be pursued to explain the mode of remuneration of
    customs officers, the mandates of the different customs squads and
    the anti-corruption struggle.

39. It is advised that the Customs should develop a progress monitoring
    tool. FIAS recommends that a systematic follow up of a number of
    key-indicators be put in place. These indicators should include at
    least the waiting time for customs clearing (average and variance
    per merchandize type, per operator) on a monthly basis, the number
    of controls and regularizations (average and variance per
    merchandize type, per operator). The progress already made in the
    automatic processing of data should make it relatively simple to set
    up these indicators. It is also recommended that these indicators
    should be published (See further herein "Adoption of Performance
    Criteria").

    *Importer/Exporter Card*

40. No administrative change occurred. The card remains an obligation.
    On the other hand, the cost of the card seems to have clearly
    increased. It is now CFAF 60,000 compared to about CFAF 16,000
    in 1998. This cost may appear to be high if you consider that it is
    mandatory for all import operations including single and small ones.
    However, the associated waiting time is very short or just within
    hours of the submission of application.

41. It is recommended that the use of the card be cancelled or at lease
    made more flexible; its use should no longer be mandatory.

    *Customs Duty Exemption Certificate*

42. The customs duty exemption certificate is necessary for companies
    whose investment program has been licensed under the Investment
    Code. Once this program has been licensed by the Minister of
    Finance, the company must obtain an exemption certificate to be
    eligible for an exemption from customs duties. The description and
    analysis of required procedures can be found in Box II-1.

43. Our first recommendation would be to cancel the customs duty
    exemption certificate by revising the Investment Code (as suggested
    earlier herein). This cancellation would allow an allocation of the
    human resources of the Customs Administration to more profitable and
    more effective activities. It would also allow a more efficient
    deployment of the Single Window staff who today spend most of their
    time managing the list of non-dutiable capital goods and customs
    duty exemption certificates. Whereas, its main role should be to
    assist investors with their formalities and to develop into a real
    formality center.

44. If the cancellation can not take place in the short term, this
    procedure might be shortened by delegating the authority for signing
    the customs duty exemption certificate to the customs officer
    appointed with the Single Window and no longer to the Customs
    Department.

45. It is also recommended that follow up within the company should no
    longer be the responsibility of APIX. It is indeed a contradiction
    for the latter to be both a private investment promoter and the
    agency controlling the use of exceptional tax systems. This dual
    role automatically arouses suspicions among investors. The customs
    or tax departements should take over responsibility for this
    inspection.

    *Tax Payments*

46. Tax administration is inevitably linked to fiscal policy. Tax
    multiplicity and complexity make things difficult not only for the
    companies but also for the Tax Authorities. The arguments in favor
    of a simplification of the current tax system are presented in the
    relevant FIAS' study and are not repeated here.

47. In the past few years, many initiatives were taken to improve the
    operation of the Taxation Authorities. These include service
    modernization and computerization, better coordination among the
    Internal Revenue Service, the Land Registry Department, the Treasury
    Department and the Customs Department and an harmonization of some
    of the practices particularly under the leadership of WAEMU. The big
    company under-department was also established following the example
    of other countries in the region.

48. FIAS' recommendations are limited and mainly aim at responding to
    the concerns expressed by the companies interviewed through the
    questionnaire. Emphasis should be laid on:

-   reinforcing the big company under-department in order to facilitate
    tax payments and an adequate control by the Taxation Authorities.
    Such an effort is crucial, for big companies provide most of the tax
    receipts (For instance, fifteen biggest taxpayers account for about
    ¾ of receipts under company tax);

-   reducing the number of forms and improving their format -- which is
    a problem for 70% of the companies surveyed;

-   making refund of VAT rebates more transparent and faster (the survey
    reported average waiting time of up to about 100 days).

    1.  Other actions obviously still need to be taken such as improving
        and making things easier for SME and ensuring greater
        transparency in controls. For a more detailed discussion of the
        subject, please refer to the recent study by GRCC.[^20]

B.  Reform Process Reinforcement[]{#__RefHeading___Toc8460588 .anchor}

    1.  At this stage, it is important to reinforce the reform process.
        The first issue is to find out what is the most appropriate
        institutional framework to support the reform of administrative
        procedures over time. The answer to this question is essential
        to validate the Plan of Action and its follow up. We shall
        propose, in particular, that the Plan of Action follow up be
        placed under the responsibility of a Secretariat. The functions
        and placing of the Secretariat under the relevant institutional
        authority are crucial to project success.

    2.  A special attention must also be paid to two other components of
        the reform process. First, international experience has
        demonstrated that it is essential to develop performance
        criteria to measure project success over time in comparison with
        other countries. The Authorities ought to include also incentive
        mechanisms to motivate the government officials who have to
        carry out the reforms. Without these mechanisms, it is clear
        that many actions will be hindered by many administrations'
        lethargy as they seek to protect their status quo. The reform
        process has the obligation to identify "winners".

        1.  The Institutional Framework []{#__RefHeading___Toc8460589
            .anchor}

    3.  The institutional framework on which efforts to streamline
        administrative procedures will be based must integrate several
        principles, viz.:

-   placing under a high institutional authority that would ensure
    reform process visibility and a transversal decision-making power
    through ministries and agencies;

-   a capacity to coordinate and to communicate with the relevant
    departments of the public administration;

-   incorporating technicians with adequate experience in administration
    and the private sector;

-   establishing a relationship with the private sector.

    1.  International experience has revealed that institutional
        solution is not unique and depends on the organisms and actors
        found in each country. Nevertheless, a survey of the countries
        that have been clearly successful in their reform effort will
        help deduce a general standard framework, integrating the
        above-mentioned principles. This standard framework is made up
        of: a) a decision-making center; b) an advisory council; c) a
        secretariat and d) technical groups.

    2.  [The Decision-making Center]{.underline}. It is necessary to
        identify a champion capable of taking the right decisions
        required by the Plan of Action. While some measures represent
        minor changes consisting in simple bureaucratic changes, other
        require changes in the law or economic policy decisions. Many of
        these decisions are also transversal in nature and involve
        several ministries and agencies. This is why it is advised that
        the decision-making center should be placed at the highest
        political level such as the Presidency, the Prime Minister's
        Office or the Council of Ministers. This high positioning also
        makes it possible to increase reform visibility and to send a
        strong signal both to investors and government employees about
        the authorities' commitment.

    3.  [The Advisory Council]{.underline}. The membership of the
        Advisory Council varies from one country to another, but the
        general guiding principle is that it includes parties to the
        reform process. It must include the key-ministries, the main
        representatives of the private sector and, in some cases, the
        main donors. The Council members must have a deep knowledge of
        reforms and be capable of leading the work of the Secretariat
        and informing the Decision Center of the progress made and the
        problems persisting over time. The inclusion of members from the
        business community is important as the latter are the main users
        of administrative procedures. They can measure actual reform
        impact, increase process transparency and advise the
        administration.

    4.  [Secretariat]{.underline}. The Secretariat is responsible for
        monitoring the implementation of the Plan of Action. This
        function includes identifying the progress made and problems
        that remain to be solved and maintaining dialogue within the
        administration and with the private sector. It must periodically
        inform the Advisory Council and the Decision Center either
        through direct consultations or a progress report. In many
        cases, it should be able to prepare a legal document or
        regulations preceding the implementation of certain measures.
        The functions of the Secretariat will be detailed further
        herein.

    5.  [The Technical Groups]{.underline}: The technical Groups must
        include the representatives of the administrations concerned by
        the multiple measures considered in the Plan of Action. For each
        important (or set of) measure(s), it is advised that a technical
        committee be set up and led by the department in charge of
        carrying out the envisaged reform. These committees must monitor
        the reforms and also ensure the internal diffusion of
        information within the administration.

    6.  It is perhaps important to describe the institutional framework
        surrounding the Decision Center, the Advisory Council and the
        Secretariat in many countries. The examples of Morocco, Latvia
        and Turkey are presented because in the past few years these
        countries have been particularly active in trying to streamline
        their administrative procedures (with the active participation
        of FIAS in the latter two). The references made to France
        illustrate the recent efforts made in this country and may serve
        as a basis for Senegal in view of the similarities between the
        political, legal and institutional structures in force in both
        countries.

Table III-2: The Institutional Framework: An International Comparison

+-----+-------------+------------------------+------------------------+
|     | **Decision  | **Advisory Council**   | **Secretariat**        |
|     | Center**    |                        |                        |
+-----+-------------+------------------------+------------------------+
| M   | King        | Royal Investment       | Unit reports to the    |
| oro |             | Council headed by the  | Governor of each       |
| cco |             | Minister of Interior   | region (it is a        |
|     |             | and the membership of  | decentralized process) |
|     |             | which includes         |                        |
|     |             | representatives of the |                        |
|     |             | public and private     |                        |
|     |             | sector                 |                        |
+-----+-------------+------------------------+------------------------+
| Lat | Prime       | Ad hoc Committee       | Investment Promotion   |
| via | Minister    | headed by the Ministry | Agency which reports   |
|     |             | of Economy with high   | to the Ministry of     |
|     |             | representatives of the | Economy and to the     |
|     |             | administration as      | Council. The Unit in   |
|     |             | permanent members      | charge is made up of   |
|     |             | including the          | about three people.    |
|     |             | Promotion Agency. The  |                        |
|     |             | Committee regularly    |                        |
|     |             | invites observers from |                        |
|     |             | the private sector     |                        |
|     |             | including the          |                        |
|     |             | « Foreign Investor     |                        |
|     |             | Council of Latvia ».   |                        |
+-----+-------------+------------------------+------------------------+
| Tur | Council of  | Coordination Committee | Unit is lodged with    |
| key | Ministers   | headed by Cabinet      | the Treasury           |
|     |             | Director of the Primer | Department and reports |
|     |             | Minister with          | to the coordination    |
|     |             | membership made up of  | committee.             |
|     |             | the head of the        |                        |
|     |             | Secretariat, 5         |                        |
|     |             | representatives of the |                        |
|     |             | public administration, |                        |
|     |             | 4 of the private       |                        |
|     |             | sector and officers of |                        |
|     |             | the technical          |                        |
|     |             | committees.            |                        |
+-----+-------------+------------------------+------------------------+
| Fra | Prime       | Commission on          | The General            |
| nce | Minister    | Administrative         | Secretariat is made up |
|     |             | simplifications (COSA) | of 11 people reporting |
|     |             | chaired by the Prime   | directly to COSA. It   |
|     |             | Minister and whose     | oversees the general   |
|     |             | other members include  | operation of the       |
|     |             | 2 Ministers, 5         | Commission:            |
|     |             | representatives of the | preparatory work for   |
|     |             | administration,        | the Commission         |
|     |             | central directors and  | sessions and           |
|     |             | 5 qualified            | implementation of its  |
|     |             | personalities (plus a  | conclusions. Il is     |
|     |             | rapporteur general).   | responsible under the  |
|     |             |                        | authority of the       |
|     |             |                        | Rapporteur General,    |
|     |             |                        | for coordination and   |
|     |             |                        | follow up of the       |
|     |             |                        | annual simplification  |
|     |             |                        | programs of            |
|     |             |                        | ministries.            |
|     |             |                        |                        |
|     |             |                        | It processes requests  |
|     |             |                        | for advice on the      |
|     |             |                        | simplification         |
|     |             |                        | measures submitted to  |
|     |             |                        | the Commission.        |
|     |             |                        |                        |
|     |             |                        | It standardizes forms  |
|     |             |                        | and tele-procedures    |
|     |             |                        | and coordinates the    |
|     |             |                        | on-line processing of  |
|     |             |                        | administrative forms   |
|     |             |                        | of State departments   |
|     |             |                        | and organisms placed   |
|     |             |                        | under its authority.   |
+-----+-------------+------------------------+------------------------+

7.  The interaction among these different structures are illustrated in
    Chart III-1 hereinafter. These interactions are relatively stable to
    the extent that the Secretariat reports to the Advisory Council (in
    some countries, the head of the Secretariat is even a full-fledged
    member of the Council). The Advisory Council reports to the Decision
    Center or to the political champion. The only noticeable differences
    are the possibility of a direct relationship between the Secretariat
    and the Decision Center. Such a relationship is a direct one in
    France (Prime Minister) and Morocco (since Governors report to the
    King) but it is not in Latvia and Turkey. The second difference is
    the possibility that the Technical Groups report only to the
    Secretariat (France) or simultaneously to the Secretariat and to the
    Advisory Council (Latvia and Turkey).

Chart III-1:

Interactions among the Organisms

8.  On the basis of the foregoing discussion, many options can be
    considered for Senegal. Of course, the following proposals are but
    indicative and cannot capture all the conceivable possibilities in
    Senegal. The options are proposed on the basis of recent experiments
    in Senegal and in view of the private sector strategy recently
    proposed by the Government.[^21]

9.  First of all, it seems that the center of the *Decision Center*
    cannot be anywhere else than the Presidency and the Prime Minister's
    Office since the decisions that must be taken are transversal or
    inter-ministerial ones. When the program was launched, the Decision
    Center had clearly been the Prime Minister who presented the Plan of
    Action to the Council of Ministers and to the President of the
    Republic. At this juncture, it seems that the Presidency has assumed
    a more active role in the private sector development strategy.

10. The *Advisory Council* might be the General Development Advisory
    Committee (CGCD) whose membership and mission are quite adapted to
    the duties described above The objectives assigned to this committee
    consist in "establishing a dynamic partnership between the private
    sector and the Government; identifying and analysing the
    difficulties and constraints confronting the private sector; and
    adopting consensual decisions to solve the above-mentioned
    difficulties and constraints with a view to enhancing company
    competitiveness".[^22] Furthermore, CGCD has the advantage of being
    institutionally connected to the Presidency (Annual meeting) and to
    the Prime Minister's Office (Quarterly meeting). Its membership is
    made up of representatives of both the private and public sectors
    while APIX assumes (on a provisional basis) the functions of a
    Permanent Secretariat. Lastly, CGCD has the advantage of being
    directly involved in donors coordination in private sector
    development, as a member of the Steering Committee of the Plan of
    Action for the Government's private sector development strategy.

11. The placement of the *Secretariat* remains the main question to be
    answered under the institutional framework in Senegal. A Secretariat
    had existed in Senegal since the development of the Plan of Action
    in 1999. In fact, its placement and membership changed over time; it
    was initially placed under the authority of the Prime Minister's
    Office and later lodged with the Ministry of Economy and Finance and
    lately with APIX. These developments reflect both institutional and
    political changes as well as staff redeployment.

12. It is beyond FIAS' mandate to decide what should be the
    institutional placement of the Secretariat. To guide the authorities
    in their decision-making, FIAS advises that they should ask the
    following questions:

-   Is there any historic or traditional reason to place the Secretariat
    within a specific agency or ministry?

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-   Will the Secretariat have access to the Decision Center?

-   Will the Secretariat have access to the administrations concerned by
    the streamlining of administrative procedures?

-   Will the Secretariat have access to the business sector?

-   Will the Secretariat have access to an adequate budget or a
    financing mechanism with enough flexibility to make it adjust in the
    course of time?

    1.  It is clear that institutionally placing the Secretariat within
        APIX offers many advantages. For instance, APIX has direct
        access to the Presidency and to CGCD which grants it visibility
        and access to the decision-making power.[^23] APIX also has a
        close contact with the business community first as a private
        investment promoter and secondly through the participation of
        private sector representatives in its management council.[^24]
        Its mandate also covers the streamlining of administrative
        procedures. Today, the main weakness of APIX is the absence of a
        clearly established relationship with the majority of agencies
        and administrations concerned by the streamlining of
        administrative procedures. In particular, there no longer seems
        to exist any formal contacts with the technical committees which
        had been established at the beginning of the program (These
        committees last met in July 2001). It may also be argued that
        APIX focuses on foreign investments while the problem of
        administrative procedures affects all companies, notably the
        small and medium-sized enterprises located in the country. And
        on top of all, APIX's has an extensive mandate covering the
        promotion of private investment up to the implementation of
        major works including the establishment of a company formality
        center. This diffuse mandate may hinder the efficient monitoring
        of administrative reforms. Under such circumstances, the
        question is whether APIX has the resources and desire to take up
        the responsibility for monitoring the implementation of the Plan
        of Action.

    2.  In taking its decision, the Government should take into
        consideration the fact that APIX is also a party to formality
        simplification (Single Window, possibly CFC) and as such, it
        would somehow "be judge and judged" in the implementation of the
        Plan of Action. This important observation was repeatedly
        expressed by the FIAS mission, which raises the issue of private
        operators, donors and other administrations' confidence in a
        Secretariat which investigates alone its own reforms and is
        understandably not prone on reducing its prerogatives -- for
        instance in so far as licensing under the Investment Code is
        concerned.

    3.  The Secretariat does not necessarily need huge resources but
        rather a limited group of motivated and qualified persons who
        devote their full time to its work. This total dedication is not
        only necessary in view of the scope of the work but this group
        should also be responsible for follow up with a clear mandate.
        While the human and financial resources will be discussed more
        in detail in the last section of this chapter, the main
        functions of the Secretariat are detailed hereinafter. They are
        not trivial and will partly determine the successful
        implementation of the Plan of Action.

    4.  The main functions of the Secretariat should be the following:

\(a\) to have a deep knowledge of the investor's roadmap;

\(b\) to lead the debate with the technical groups;

\(c\) to maintain a dialogue between the Government and the private
sector on the follow up of the Plan of Action;

\(d\) to inform the Coordination Committee and the Decision Center of
the possible problems that emerge as the Plan of Action is being
implemented;

\(e\) to monitor the impact of the measures contained in the Plan of
Action, which requires:

-   the establishment of formal and rigorous mechanisms through which
    each department concerned reports reforms status to the Secretariat,
    meaning the progress achieved or possible problems;

-   the quantitative assessment of reform impact on the investor's
    roadmap, in terms of time and financial costs through system users'
    reaction including a periodic company survey;

-   regular reporting on reform status to the Coordination Committee and
    the Decision Center.

5.  Apart from five main functions, the Secretariat may have to
    discharge additional duties such as maintaining adequate
    relationship with the media and the donors that are likely to play
    an important role in propagating the information on both progress in
    reforms and funding of specific activities.

6.  For the Secretariat to successfully carry out its functions, it must
    be more than just an administrative agency where investors would
    come to complain and a mere [gangway to accede the Advisory
    Committee]{.mark}. The Secretariat must act in a proactive way both
    in terms of its contacts with the business community and the
    administrations concerned. In discharging its duties, it must show
    competence and perseverance. This is why the selection of the
    Secretariat Staff is essential.

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1.  Adoption of Performance Criteria []{#__RefHeading___Toc8460591
    .anchor}

    1.  The follow up of the Plan of Action not only requires an
        adequate institutional framework but the adoption of performance
        criteria as well. As argued in the preceding chapter, one of the
        major weaknesses of the approach followed so far is the absence
        of quantitative criteria with which to assess the real impact of
        reforms on the investor's roadmap.

    2.  While the Plan of Action is being adopted, it is essential to
        associate targeted objectives in terms of time and financial
        costs with a majority of administrative procedures. These
        quantitative objectives are not only useful to evaluate reform
        efficiency but they also facilitate reform monitoring by
        formalizing the commitment of administrative departments the
        responsibility of which is then to produce the assigned
        objectives. As pointed out, import procedures would be an
        excellent application of such an approach.

    3.  The starting point might be to reduce the waiting times reported
        in chapter I of this report (Table I-4). Some objectives might
        be set in such a way as to gradually reduce these waiting times
        over time (For example, licensing under the Investment Code
        might be granted from within 14 days as is the case today, to
        within 10 days in 8 months' time and within 8 days in a year's
        time). Others might be set based on best international or
        regional practices (For example, company registration with the
        commercial court might be done in a day or two as is the case in
        Tanzania).[^25] FIAS can assist the Authorities in this exercise
        with its international experience. The definition of these
        objectives must be discussed and validated by each
        administrative department concerned.

    4.  It is important to agree on quantitative objectives but also on
        the methods that will be used to verify them. Two complementary
        approaches can be used. The first one is simply to ask the
        administrative departments concerned to periodically report the
        progress achieved for instance on a monthly or quarterly
        basis.[^26] The second approach is to receive periodic
        evaluations by the private sector either through regular
        interviews with focus groups such as unions or employers'
        associations, legal advisors working with investors or through
        periodic surveys of a large number of contractors. The survey
        accompanying this study may serve as a reference for the future.

    5.  Apart from setting quantitative objectives for reform impact, it
        is recommended that deadlines for reform realization be included
        in the Plan of Action. These deadlines had been previously
        included in the Plan of Action but most of them have already
        expired and therefore need to be readjusted.

    6.  As in the current plan, it is important to specify what
        department or administration is responsible for the
        implementation of each measure. This identification also needs
        to be updated.

2.  An Incentive Mechanism []{#__RefHeading___Toc8460592 .anchor}

    1.  The implementation of the Plan of Action will be based on the
        operation of the institutional framework and the establishment
        of performance criteria. These two conditions are important but
        it is also essential to motivate the government employees who
        will be actually responsible for carrying out these reforms. If
        they are not motivated, it is then very likely that the proposed
        reforms will be hindered by lethargy and that the streamlining
        of the investor's roadmap will be slowed. The importance of the
        relationship between the need to develop a good governance and
        the success of administrative reforms is highlighted in the last
        chapter.

    2.  FIAS recommends the adoption of a control and reward policy.
        Control is clearly the responsibility of the Decision Center
        whose role is precisely to ensure that the measures identified
        in the Plan of Action are taken. For this purpose, the Decision
        Center should resolutely take all necessary administrative and
        policy measures. It must "practice what it preaches".

    3.  A complementary approach is to ensure transparent results by
        disseminating them within the administration and among the
        public. Transparency makes it possible to identify good and bad
        results. Diffusing the Plan of Action follow up and the results
        obtained from company survey in the press and on television is
        generally an efficient way of demonstrating the government's
        will for a change and securing greater participation of the
        departments concerned.

    4.  Control policy is necessary but not sufficient to obtain results
        in the medium and long terms. It is also essential to put in
        place reward mechanisms for the departments or government
        employees that have adopted the measures contained in the Plan
        of Action and have thus contributed to enhancing the investor's
        roadmap. Like in any reform process, it is useful to identify
        "winners" for there will always be "losers" who will seek to
        maintain the status quo.

    5.  Incentive mechanisms may be of a technical or financial nature.
        Thus, the departments that have improved their performance can
        be rewarded financially for their efforts. Considering
        individual incentives for government employees turned out to be
        an important element in the progress made by the Customs
        Department in terms of customs clearing time (See Box III-5).

    6.  Other countries like France have instituted an annual reward for
        the department that proposes the most efficient streamlining of
        procedures with which it is associated. This approach has the
        advantage of favoring reform dynamics since the initiative not
        only emanates from the Plan of Action but it is also perpetuated
        by the administration itself. The successful outcome of these
        initiatives highly depends on the degree of visibility granted
        to them by the political authorities including the Head of
        State.

    7.  Technical support is important especially for the departments
        which are asked to improve performance and productivity. This is
        the case for example of Company Formality Center, Land Registry
        and Tourism Department. This support can take two forms: a)
        training and b) equipment and systems. These two forms of
        support are more detailed hereinafter in the section dealing
        with the evaluation of project funding needs.

+-----------------------------------------------------------------------+
| ######                                                                |
|                                                                       |
| ###### Box III-5 : Customs : Change Factors                           |
|                                                                       |
| Since 1998, the customs clearing procedure has been significantly     |
| improved from more than a week to about three days. The following     |
| factors appear to have played a decisive role in the achievement of   |
| this progress.                                                        |
|                                                                       |
| ##### Taking into account incentives for government employees         |
|                                                                       |
| #####                                                                 |
|                                                                       |
| ##### The                                                             |
| streamlining of the mode of remuneration has contributed to reducing  |
| the employees' personal encouragement to effect "wild" inspections wh |
| ich are normally remunerated under over time assignments. While they  |
| continue to exist, these assignments have now been equitably distribu |
| ted among customs officers and better controlled by the management no |
| tably through a system of payment by coupons delivered by the Adminis |
| tration itself. These measures seem to have helped reduce, indeed, th |
| e number of controls thus speeding up the customs clearing procedure. |
|                                                                       |
| ##### International Reform Dynamics                                   |
|                                                                       |
| The introduction of WTO's valuation standards in 2001 which is based  |
| on the commercial value of goods has contributed to reducing          |
| conflicts with importers hence to speeding up the procedure. The fact |
| that these are international standards not enacted at the national    |
| level seems to have played an important role in increasing the        |
| confidence of private operators in the customs.                       |
|                                                                       |
| ####### Reinforcement of Data Processing Tool                         |
|                                                                       |
| Speeding up the customs clearing procedure was also made possible by  |
| enhanced data processing both in terms of the hardware and software   |
| used. Apart from the fast processing per se, enhanced data processing |
| has made it possible to develop more efficient inspection and         |
| inspection controls. For instance, inspections are now partly decided |
| automatically on the basis of the operator's history criteria and the |
| origin and type of goods. This system limits the scope of individual  |
| arbitrariness.                                                        |
+-----------------------------------------------------------------------+

> C. An Estimate of Funding Needs []{#__RefHeading___Toc8460593 .anchor}

8.  The implementation of the Plan of Action requires the Government's
    political and financial commitment as many of the measures will
    necessitate the modernization of the systems used by the
    Administration and training to support behavioral and technical
    changes within the departments concerned. In the case of Senegal,
    this financial support may not only come from the Government but
    also from donors who have demonstrated an unfailing will to
    accompany the Authorities in their efforts to streamline
    administrative procedures in the country.

9.  An estimate of the funding needs proposed hereinafter by FIAS is but
    a preliminary one. It must necessarily be complemented while
    finalizing the plan and when the Secretariat will be effectively
    operational. Needless to say that this should be one of the primary
    functions of the Secretariat. In this context, three priorities are
    described hereinafter, viz. a) Secretariat funding; b) logistical
    support to the Formality Center and the Land Registry, which will
    constitute two priority projects on the reform schedule, and c)
    technical support to training which must accompany the setting up of
    many actions within the administrative departments.

1\. Funding of the Secretariat []{#__RefHeading___Toc8460594 .anchor}

10. The role of the Secretariat is crucial for the successful adoption
    and follow up of the Plan of Action. Its main functions have been
    described earlier herein. The focus here will be on its financial
    needs. FIAS estimates that a budget of about US\$ 100-125,000 would
    be necessary for the smooth operation of the Secretariat.

11. The Secretariat's major financial need is the funding of its staff.
    International experience has demonstrated that there is no need for
    too many staff (For example, the staff strength is 11 in France, but
    their functions cover the administrative procedures that every
    citizen must go through and not only companies. The staff members do
    not exceed 3 in Latvia). FIAS advises that in Senegal the
    Secretariat should consist of a director and one or two professional
    staff. An assistant would also be necessary.

12. The Secretariat staff should have a deep knowledge of the investor's
    roadmap and the administrations concerned. Their qualities and
    profiles can be summarized as follows: a) commitment; b) will to go
    into details; c) flexibility and persuasive force; d) easy
    contact; e) political neutrality. They should have vocational
    training in law, economics or public administration and preferably,
    an experience with the private and public sectors.

13. it is difficult for FIAS to put a figure on the remunerations of the
    Secretariat staff. These should be comparatively equivalent to the
    remunerations associated with positions of similar importance within
    APIX..

14. Another expense of the Secretariat concerns periodic company survey
    (Once a year) or about US\$15,000.

15. one particular feature is that while the Secretariat is being
    established, a training budget should be provided for. For instance,
    the CEO of the Secretariat might benefit from a "training trip" in
    various countries like a visit to COSA in France. An initial budget
    of US\$15,000 might be anticipated for this purpose.

######### 2. Logistic Support to Two Priority Projects 

16. Procedure streamlining in Senegal is partly based on two priority
    projects which will require substantial efforts both technically and
    financially.

17. The first priority project consist in enhancing the service of the
    Land Registry. At this juncture, it constitutes a major obstacle to
    access to land. It is necessary to computerize the Land Registry in
    order to ensure good keeping and management of land titles, to
    recruit technicians and inspectors and make available to them
    working tools and utility cars to carry them onsite. A project on
    the establishment of a land register for the territory should also
    be supported. A similar project had already been successfully
    undertaken by the Land Registry, with the assistance of one of the
    donors for the city of Ziguinchor. If this experiment is conclusive,
    it should be set as an example and extended to other communities.
    The budget required might be adjusted on this basis.

18. The second priority project is the establishment of a company
    formality center. This project should be divided into two stages.
    The first stage would consist in harmonizing application forms for
    several registration procedures like tax registration with CSS,
    IPRES and the commercial court. Such an harmonization should not
    only facilitate investor's formalities but also the work of the
    administrations concerned. Eventually, it should enable them develop
    common data bases which should limit tax evasion and facilitate
    controls. The second stage would be the networking of these
    different registration procedures. At this second stage, as already
    pointed out, the Authorities should wonder about the relevance of
    using the experience acquired with Trade Point while developing the
    customs clearing information exchange system.

19. FIAS warns that though these two stages are inter-related, it
    prefers to separate them because it does not want to give the
    impression that the company formality center exclusively depends on
    an adequate data processing system. "Better is the enemy of good"
    and the establishment of a computer network may take away the
    Authorities from concrete objectives which are crucial in the short
    term.

20. It is difficult to put a figure on the total budget required to
    fully set up the formality center. In a first step, the departments
    concerned must receive technical advices on the methods used to
    harmonize procedures in other countries. This assistance is an
    occasional one and should not be costly.

21. In any case, one of the primary duties of the Secretariat should be
    to put a figure on the financial needs of these two projects. As
    priority projects, they should normally benefit from a substantial
    part of the total resources mobilized to implement the Plan of
    Action.

######### 3. Technical Assistance and Training in Administration 

22. In addition to the priority projects and in accordance with the
    incentive logic suggested earlier herein, it is proposed that a
    *Reform Fund* should be established. This Fund would be used to
    support administrations that would submit to the Government an
    individual reform plan in conformity with the Plan of Action. In
    return for the Fund's support, these administrations would pledge to
    shorten the waiting time associated with the targeted procedure, or
    possibly to achieve specific qualitative objectives. These
    objectives will have to be defined prior to the reform envisaged and
    the corresponding indicators would be published as the reform
    continues. Preferably, assistance would be granted in many steps
    each of which is conditioned on the realization of a given level
    objective.

23. The assistance provided by the Fund might cover organizational
    counseling, training and computerization. In any case, this
    assistance must directly contribute to enhancing administrative
    procedures. And the Fund might even be used to retrain the staff of
    the departments that had been cancelled or reduced in size as a
    result of the cancellation of irrelevant procedures. The Fund would
    be managed by the Decision-making Center while the Secretariat would
    be in charge of processing the applications.

24. The following are some of the reforms which the Reform Fund can
    support:

-   Tourism Department: reinforcing hotel inspection;

-   DGI/Big Company Management: upgrading the processing of big company
    taxation;

-   Interior Department: speeding up delivery of foreigner ID card;

-   Environment Department: institutional resource reinforcement plan;

-   Industry Department: cancellation of attestation requirement;

-   Livestock Department: cancellation of licensing requirement for
    tanneries.

-   Labor Department: ending employment contract signing requirement for
    "displaced" workers;

-   External trade Department: cancellation of the importer card
    requirement.

    1.  The initial resources of the Fund might be about US\$100,000.
        These resources should make it possible to test the incentive
        effect of the approach and to decide possibly on deepening it.
        The Fund would be primarily financed from the State budget,
        notably in agreement with the Civil Service Reform.

**APPENDIX **

**DESCRIPTION OF ADMINISTRATIVE PROCEDURES**

**IN MARCH 2002**

1.  The purpose of this Appendix is to describe the administrative
    procedures which an investor must fulfill when he/she wants to set
    up business and operate in Senegal. The procedures described
    hereinafter are found along the administrative roadmap which had
    been identified in the first study conducted by FIAS in 1998. Owing
    to this and in order to avoid repetitions, our presentation focuses
    only on the changes that have taken place and on the details that
    had been omitted in FIAS' first study. A special attention is
    devoted to the formalities associated with access to lands and site
    layout, which remain extremely complicated and in which many changes
    have been introduced over the past few years.

2.  For each procedure, the contact persons within the ministries and
    agencies have been updated.

A. GENERAL FORMALITES

> 1\. Licensing under the Investment Code and as a Free Export
> Processing Company

*National Investment Promotion Agency (APIX)*

*52-54 Rue Mohamed V,*

####### BP 430

*Dakar*

*Hamath Sall*

*Director of the Single Window*

*Tel.: (221) 849 05 55*

3.  The Window is responsible for licensing under the Investment Code
    and as a Free Export Processing Company. Since mid-2000, the Window,
    which was previously lodged with Ministry of Finance has now been
    integrated in APIX.

4.  To the extent that the legal texts have remained unchanged -- in
    particular, the Regional Investment Code has not yet been approved
    -, procedures have not been significantly modified. However, a
    number of institutional and administrative actions have contributed
    to a substantial shortening of waiting times. This progress which
    was made under the aegis of APIX include:

-   reducing the size of the application form, more specifically
    dropping of the feasibility study requirement;

-   appointing a customs representative with the Single Window thus
    speeding up control of the capital goods and materials that are
    likely to be exempted from customs duties and VAT;

-   online provision of the licensing application form by APIX from its
    Website.

> 2\. Company incorporation

######### *Commercial Court*

*Trade Register*

####### Dakar

*Contact person: Mr. Dieng*

*Deputy Chief Registrar*

*Tel.: 821 51 30*

5.  No major change has been reported in company incorporation
    procedures other than a better integration of decisions from the
    OHADA framework.

> 3\. Registration Formalities
>
> a\. Tax/Statistical Registration

*Direction des Impôts et des Domaines (Internal Revenue and State
Property Head Office)*

*Ministry of Economy and Finance*

*Bloc Fiscal (Internal Revenue Service Building)*

*B. Ndao*

*Tax Collection/Dispute Head*

####### Tel.: 823-69-69

*Forecasting and Statistics Department (DPS)*

*Ministry of Economy andFinance*

####### Rue 1, Boulevard de l\'Est, Point E

*Dakar*

####### Mr. Magatte Wade

*NINEA Office*

*Tel.: 824 03 01; 825 00 50*

6.  Since January 2002, the Authorities have enforced the 1995 Law
    unifying the formalities for tax and statistical registration. In
    principle, a single form (known as the "Single Form") and a single
    number (the NINEA) are required for the private operator who now
    only has to go to his/her area branch office of the Internal Revenue
    and State Property Head Office (DGID) to obtain his/her NINEA;
    he/she initially also had to go the Forecasting and Statistics
    Department. In practice, however, the system is not fully
    operational due to its recent introduction.

7.  It is important to note that APIX's Single Window plays a role as a
    promoter for licensed companies (only) that are seeking to obtain
    their NINEA number.

> b\. Affiliation to the Social Security Fund

*Caisse Sécurité Sociale(Social Security Fund)*

*Place de O.I.T.*

*B.P. 102*

*Dakar*

####### 

####### Mr. Laye

*Tel. : 8216815*

8.  The situation has not changed since 1998. The procedure for
    affiliation to the Social Security Fund (CSS) is still the same
    including the required attachments, waiting time and costs. The
    formality does not entail any financial cost and the associated
    waiting time is estimated at one week starting from the day of
    submission of full application.

9.  CSS is not aware of the "Single Form" project but it finds the idea
    interesting and would be willing to cooperate.

c\. Affiliation to the Senegal Social Provident Fund (IPRES)

####### Senegal Social Provident Fund (Institut de Prévoyance Retraite du Sénégal)

*22, Avenue Roume*

*B.P. 161*

*Tel.: 821 55 27*

10. No change has been reported since 1998. The affiliation procedure
    remains the same including the required attachments, waiting time
    and costs. The procedure does not entail any financial cost and the
    associated waiting time is estimated at one week starting from the
    day of submission of full application.

11. The "Single Form" is therefore not used by IPRES and so far no
    project of this nature is under way. IPRES was reportedly invited in
    1999/2000 to meetings dealing with this theme, but according to
    those in charge, this project was disregarded. The principle of a
    single form is however found positive and IPRES would again be
    willing to cooperate.

d\. Labor Inspection -- Notification of Company Opening

*Labor Department*

*1^st^ floor - Room 101*

*A. Diouf*

*Tel.: 823 5908*

12. No change has been reported since 1998. The notification of company
    opening to the Regional Labor Inspection remains therefore an
    obligation and is done on the same conditions as previously. The
    formality does not entail any financial cost and the associated
    waiting time is estimated at one week starting from the day of
    submission of full application.

13. The Ministry of Labor and Employment, which is the authority
    supervising the Labor Inspections has never been associated with the
    work on the single form but agrees with the principle.

4\. Other Formalities

> a\. Foreigner ID Card

*Immigration Police*

####### Ministry of Interior/Foreigner ID Card 

*Mr. Babacar Ly*

*Senior Inspector*

*Tel. : 822 38 08*

14. No major change in the foreigner ID card application procedure has
    been reported since 1998. The settlement authorization is still
    required for foreigners by the Ministry of Interior.

> b\. Registration of Foreign Investment

*Money and Credit Department (MCD)*

*Ministry of Economy, Finance and Planning*

*Mr. Siporo*

*Tel. : 648 61 98*

15. No change in the procedure has been reported since 1998. Direct
    foreign investments must always be declared.

> c\. Registration of Brands and Patents

*Intellectual and Technological Property Service (ITPS)*

*Industry Department*

*104, Rue Carnot, B.P. 4037*

*Mr. D. Sagna*

*Tel. : 821 15 42*

16. No change in procedure has been reported since 1998. Registration is
    still done at the regional level with the African Intellectual
    Property Organization (AIPO).

B. SPECIALIZED LICENSING

> 1\. Mining

*Mining and Geology Department*

*Ministry of Energy, Mining and Industry*

*104, Rue Carnot*

*Dakar*

####### 

####### Mr. E. Faye

*Tel. : 822 04 19*

17. The authorization application procedures have not changed
    since 1998. It seems that all the recommendations made by FIAS in
    its first report have been incorporated in the new Mining Code
    Project, which should be submitted to Parliament in the coming
    months.

> 2\. Tourism

*Ministry of Tourism and Air Transportation (MTAT)*

*B.P. 4049*

*Dakar*

*Mr. Sy*

*Tel. : 821 11 26*

18. No major changes have been reported since 1998. The licensing
    application procedures for a travel and tourist transport agency
    remain the same.

19. The only reported change is that hotel licensing is no longer
    subject to the prior authorization of the Ministry of Tourism.
    However, when license is granted by the Single Window, the Ministry
    of Tourism still demands an opening and operation authorization from
    the economic operator.

20. Once licensing under the Investment Code has been delivered by APIX,
    the investor applies to the Ministry of Tourism for an authorization
    to open and operate the agency. The staff of the Ministry of Tourism
    then verify whether the buildings on the site correspond with the
    estimates on the basis of which the license was obtained. In most
    cases, failings were reported (For example, health and security
    standards are not complied with; employees are not recorded with the
    social security, etc...). In fact, it seems that the Ministry staff
    go onsite only once in ten applications submitted. The remaining
    nine cases are never verified. Following their inspections, the
    Ministry staff then prepare a report which is submitted to the
    Minister.

> 3\. Fishery

####### Oceanography and Sea Fishery Department

*1, Rue Joris*

*B.P. 289*

*Dakar*

####### Mr. Thiam

21. No major change has been reported since 1998. More specifically, no
    progress was made, not even under research or reflection, towards a
    fishery licensing mechanism by auction.

The only minor change was to make (annual) license renewal slightly more
constraining by adding a boat insurance certificate to the list of
required documents.

22. The fishery licensing and license renewal application procedure does
    not entail any financial cost but it induces the payment of fishery
    dues, which vary according to the type of license (fished species)
    and boat tonnage. The waiting time associated with this procedure is
    estimated at one month for initial licensing and equal period of
    time for renewal starting from the day of submission of full
    application.

> 4\. Bank and Insurance Companies

*Central Bank of West African States (BCEAO)*

*Dakar National Branch office*

*B.P. 3159*

####### 

####### Mr. Abdoulaye Gaye

####### Head of the Research Division

####### Tel. : (221) 823 53 84

##### 

##### Insurance Department

*Ministry of Economy, Finance and Planning*

####### 

####### Mrs. Mariam Diouf 

####### Tel. : 849 58 88

23. [Bank]{.underline}. No noticeable change has been reported singe
    1998, but the situation was then deemed satisfactory. The licensing
    procedure was even noted to have slightly improved with the
    introduction of the single licensing now granted for the WAEMU[^27]
    Area as a whole. The single licensing does not entail any financial
    cost and the regulatory waiting time for BCEAO's (The Banking
    Commission) response is a maximum of three months.

24. [Insurance Companies]{.underline}. No change has been reported in
    the licensing formalities but once again the situation was deemed
    satisfactory in 1998.

> 5\. Industry

*Industry Department*

*Ministry of Energy, Mining and Industry*

*104, Rue Carnot*

*Dakar*

####### 

####### Mr. Dieme

*Tel. : 821 15 42/44/45*

25. No change has been reported in the delivery of the attestation
    entitling to preferential rates. However, the procedure is
    irrelevant in view of the changes in the customs regime within WAEMU
    except for the "industrial" sugar for which tax exemptions are
    granted. The procedure has been maintained especially for
    statistical data collection purposes.

> 6\. Leather Goods

*Livestock Department*

*Ministry of Livestock*

*37, Avenue Pasteur*

*Dakar*

####### 

####### Mr. Diouf 

####### Tel. : 823 55 09

26. No official change has been reported in the tannery licensing
    procedure, which therefore remains an obligation. However, some
    administrative vagueness seems to have developed since 1998. All the
    most recent licensing cited by the Livestock Department date back to
    1999 whereas the same Department reports that new tanneries have
    been established more recently. It appears therefore that, in
    practice, licensing is no longer necessary to carry on tanning
    activities.

27. Nevertheless, this *de facto* and even *de jure* flexibility does
    not appear to be a satisfactory solution. If this licensing does no
    longer play a relevant role in the current context, it should be
    clearly cancelled as suggested by FIAS. Besides, this cancellation
    should induce a redeployment of administrative resources within the
    department, which is not presently the case since the staff
    officially in charge of licensing have been maintained.

> 7\. Arts and Crafts

*Ministry of Handicraft And Industry (MHI)*

*Arts and Crafts Department*

*Mr. Amar Thiam*

*Head of the Research Division*

*Tel. : 823 89 92*

28. There two procedures associated with the arts and crafts: the
    establishment of cooperatives and that of Economic Interest grouping
    (EIG)

29. [Cooperative]{.underline}. This legal form is very much in demand by
    craftsmen because like associations, it is entitled to profit tax
    exemption. On the other hand, the cooperative licensing procedure
    appears to be particularly complex. The following are the main
    stages:

30. The licensing application is submitted to a Joint Commission chaired
    by the governor of the region. The membership of this Commission
    includes the local authorities and representatives of the Guild
    Chamber.

31. If the application is approved by the Joint Commission, it then
    makes it way to the central echelon within the Ministry of
    Agriculture. Where application relates to arts and crafts, it is
    forwarded to the Arts and Crafts Department, which is a division of
    the Ministry of Handicraft and Industry (MHI) and falls under the
    joint supervision of both ministries.

32. It may take up to several months to complete this procedure which
    seems to be particularly uncertain.

33. EIG is a legal innovation introduced in OHADA[^28]. An EIG
    establishment procedure is similar to that for companies with the
    main stage being registration with the Trade Register, an extremely
    simplified incorporation procedure. It does therefore not require
    any licensing. In fact, an EIG can be very quickly established
    within just a few days. The fee payable is CFAF 6,000.

C. ACCESS TO LANDS AND SITE LAYOUT

> 1\. Access to Lands

34. Access to land ownership is still the major barrier along the
    investor's roadmap. And this is a persistent problem because up till
    now only 10% of the Senegalese lands are registered. These lands
    belong to 1) the State public property and can therefore not be
    privately acquired, 2) to the State private property and can
    therefore be transferred to a third party, and 3) to individuals
    holding a land title. The rest of the lands, that is 90% of the
    Senegalese territory, is still classified as a national property and
    remains therefore unregistered. This does not prevent individuals
    from occupying these lands by virtue of the simple right of user and
    without a land title.

35. Because of the limited registration of the territory, it up to the
    investor himself/herself to identify adequate lands. A potential
    investor looking for a land for his/her project basically has three
    options:

36. identifying a national property land and initiating the acquisition
    procedure with the State departments. These procedures, as we shall
    see further herein, remain complicated and the associated waiting
    times are extremely long;

-   acquiring a privately-owned land. In this case, the procedure is
    clearly shorter, but on the other hand, acquisition costs are much
    higher. Additionally, the limited area of already registered
    privately-owned lands (estimated at 5-6% of the territory)
    considerably restricts the investors' choice especially as far as
    large-scale projects are concerned;

-   searching for a land in an industry development zone such as the
    Dakar Industrial Zone, the Dakar Technopole or the Export Processing
    Free Zone;

37. Each of these options is described in detail hereinafter.

> i\. Acquiring National Property Lands

*Direction Générale des Impôts et des Domaines (Internal Revenue and
State Property General Head Office)*

####### Direction des Domaines de l'enregistrement et de Timbres (State Property, Registration and Stamp Department) 

*Mr. Alle Sine*

####### Director of State Property

####### Tel.: 823 54 56

38. The national property is made up of 1) classified zones earmarked
    for special use (For example forests), 2) pioneer zones meant for
    large-scale land-use planning managed by the State (For example the
    Senegal River farming project), 3) Urban zones and 4) rural lands
    devoted to agriculture, stockbreeding and fishery. Only the State
    has the power to downgrade or reallocate national property lands to
    the State private property. Once transferred into the State private
    property, these lands may be made available to individuals under
    different terms. The most common way of acquiring the State private
    property is to contract a long lease (See FIAS' 1999 report for
    further details on acquisition terms). Since 1994, an individual who
    has contracted a long lease has an option to buy his/her land after
    developing it.

39. The length of national property land acquisition procedure may vary
    according to land location. Lands located in the rural areas are
    administered by the rural communities under the supervision of the
    prefecture. It is up to the Rural Councils to decide on their
    allocation. As a result, the acquisition of these lands takes a
    longer procedure than for the lands pertaining to the other zones,
    which are under the direct responsibility of the State Property
    Department. As most of the available national property lands (about
    80%) are to day found in the rural areas, obtaining the positive
    response of the Rural Councils becomes an important stage in the
    process of acquiring State property lands.

40. **Application to the rural community** -- the investor sends to the
    Chairperson of the Rural Council an application letter in which
    he/she indicates the location and area of the land that he/she
    intends to acquire. The Chairperson then convenes a meeting of the
    Rural Council whose membership include 20 to 30 representatives
    according to villages. The latter are chosen among the community
    residents, government employees, representatives of agricultural
    cooperatives, members of the Rural Expansion Center and include any
    other person whose advise is deemed useful by the Council.

41. The Council examines the application and a minutes of its
    deliberations is produced. If the land is occupied by individuals
    according to the right of user (without land title), the buyer is
    requested to pay them adequate compensation before he can obtain the
    positive response of the Council. When the response to the
    reallocation of a national property land to the State private
    property is positive, the investor can move to the next stage and
    file his/her application with the State Property Department.

42. It is difficult to predict how long the buyer will have to wait to
    obtain a positive response to the reallocation of a land located in
    the rural area. Nevertheless, in view of the number of opinions
    sought within the Rural Council and taking into consideration the
    procedure for compensating individuals who hold the right of user,
    this phase can take a relatively long period though there is no
    direct costs involved in application processing.

43. **Application to the State Property Department** -- The investor can
    now file, along with a copy of the minutes of the Rural Council,
    his/her registration application with the State Property Head Office
    (the other attachments to the application are listed in FIAS' 1999
    report).

44. The State Property Department (SPD) then instructs the Land Registry
    (LR) to look into the technical aspects of the application. LR is
    instructed to make the land survey and to establish the
    corresponding topographic map. This clarification of the land status
    is a slow process which may take up to two months.

45. Then SPD must launch a public inquiry. This is also a very long
    process as it implies the settlement of all possible disputes about
    the land during this period. In fact, the registration notice is
    publicly posted for three months within the local communities and
    possible oppositions to the land registration are considered. In the
    absence of any opposition, the application is forwarded to the
    Property Operations Control Commission. In the event of any protest,
    the waiting time is considerably extended.

46. The Commission, which is chaired by the representative of the
    Minister of Finance is made up of members of various departments
    such as SPD, Land-Use Planning, LR and Town Planning. It mainly
    considers the financial aspects of the project (Investment program
    and financing) and determines the land rent according to the current
    scale.

47. If the Commission responds positively to the application, the
    Minister of Finance still has to decide on the Commission's
    recommendation following which an attestation is delivered to the
    applicant pending final registration. The investor can then start
    marking the land boundary.

48. Boundary marking can be done either directly by LR or a private land
    surveyor under the supervision of LR. Most investors prefer to hire
    the service of a private land surveyor even though this is much more
    expensive. The waiting time for land marking is estimated at one to
    two weeks where a private land surveyor is employed while it may
    take up to two months for LR to do the same job.

49. With the attestation, a lease is prepared and the applicant can take
    possession of the land by making a deposit of up to a year's rent
    and a down payment on the first rent due. While preparing the lease,
    stamp duty and registration fee as well as the costs of land
    formalities are also calculated but are only payable when the
    registration procedure is completed. These fees are as follows:

-   stamp duty: FCFA 2000 per page;

-   registration fee: 5 % of annual rent;

-   land keeping fee: 1 % to 3 % of annual rent.

50. At this stage and in the absence of any opposition, the investor has
    already spent eight to ten months occupying the land on the strength
    of an attestation. It may take another one year or more before
    obtaining the final land registration and land title which is done
    by presidential decree and requires the signatures of many
    personalities: the Director of State Property, the Director General
    of State Property Department, the Minister of Finance, the Prime
    Minister and the President. The application might be delayed for
    months at each of these stages. The decree must then be published in
    the Official Journal which is very irregularly published. The
    reported waiting time is a minimum of two months.

> ii\. Acquiring Privately-owned Lands

51. No major change has been reported in the privately-owned land
    acquisition procedure since FIAS' last report. The investor must
    always refer to a notary who will launch an investigation to find
    out the actual legal status of the land (verifying land availability
    and identity of seller as the owner) and prepare the sales
    agreement. These operations can be completed within a few days.

52. The prior authorization of the Taxation Authorities (Law 77-85 dated
    August 10 1977) for property sale transactions in excess of CFAF 10
    million is always necessary before signing the bill of sale. The
    decree on the application of this law (77-554 dated 20
    September 1977) allows the administration two months to deliver the
    authorization. If the investor did not receive an answer to his/her
    application until the end of the specified period, the authorization
    is deemed granted and the bill of sale signed. According to the
    notaries, it takes an average of one month to obtain the
    authorization and about a week to finalize the bill of sale.

53. The costs entailed by the establishment of the bill of sale are
    described in the following Table. They include registration fee,
    notaries' honoraria, taxes payable to the State and other
    administrative costs.

Costs of Acquiring Privately-owned Lands

+----------------------------------+-----------------------------------+
| Categories                       | Costs                             |
+----------------------------------+-----------------------------------+
| Notary's Honorarium              | On a sliding scale:               |
|                                  |                                   |
|                                  | 4.5 % up to CFAF 1 million        |
|                                  |                                   |
|                                  | % % % up to CFAF 3 millions       |
|                                  |                                   |
|                                  | 1.5 % % % up to CFAF 7 millions   |
|                                  |                                   |
|                                  | 0.75% beyond CFAF 7 millions      |
+----------------------------------+-----------------------------------+
| VAT                              | 18% of Notary's honoraria         |
+----------------------------------+-----------------------------------+
| Bill of Sale Registration Fee    | 15% of sale price (with the       |
|                                  | possibility of receiving a 5%     |
|                                  | rebate if land is developed       |
|                                  | within three years of acquisition |
+----------------------------------+-----------------------------------+
| Transfer Fee                     | 1% of sale price                  |
+----------------------------------+-----------------------------------+
| Capital Gain Tax                 | 15% (of sale price minus purchase |
|                                  | price adjusted for inflation      |
|                                  | minus the costs entailed by the   |
|                                  | bill of sale).                    |
+----------------------------------+-----------------------------------+
| Stamp Duty                       | Set at CFAF 75,000                |
+----------------------------------+-----------------------------------+

> iii\. Land Acquisition in Specially Planned Zones

54. Apart from the State and privately-owned lands, investors also have
    the option to set up business in one of the three specially planned
    areas for industrial and commercial activities: the Dakar Industrial
    Zone, Technopole and the Export Processing Free Zone.

> a\. The Dakar Industrial Zone

####### SODIDA

*Mr. Fara Ndiaye*

*Director General*

*Tel.: 865 2054*

55. In its last report, FIAS indicated that the company managing the
    Dakar Industrial Zone (SODIDA) was short of available lands and was
    trying to develop a new site for the companies that were on the
    waiting list. Today, the SODIDA Industrial Zone hosts 67 companies
    on 7 hectares of lands and the SODIDA II Project; the second
    Industrial Zone is well under way. After 6 to 8 months of successful
    negotiations with the rural communities, 50 hectares of lands have
    been obtained in Diamniado and site layout will be started soon. In
    fact, based on SODIDA's experience, the General Management has
    decided to make of SODIDA II a pre-planned area where the companies
    that are interested can start production immediately after their
    installation.

56. The General Management of SODIDA II is in the process of refining
    company eligibility conditions and selection criteria. Compared to
    SODIDA, company selection procedures will be shortened for the
    second zone and the licensing decision will no longer be taken by a
    Selection Committee (with the intervention of the Board of
    Directors) but rather by a Committee within the General Management
    of SODIDA. The Management envisages granting licensing within two
    days. The eligibility conditions will also be made more flexible so
    that all companies and not only the small and medium-sized
    enterprises can gain access to the zone. Value-added generation and
    employment criteria and regional development will be the dominant
    criteria. Though the first phase of building construction on the
    site will start only in June 2002, 400 companies are already on the
    waiting list of SODIDA II.

57. Application processing will cost CFAF 22,000. Acquisitions will be
    made on a hire-purchase optional basis over a period of ten years
    and the investor will be asked to pay a deposit representing 15% of
    the total cost of a building. Once the investor has paid the monthly
    installments spread out over a 10-year period, he/she is entitled to
    a land title. Although the cost of the buildings has not yet been
    finally determined, a first estimate put it at between CFAF 20 to
    CFAF 85 million for buildings covering an area of 100 to 600 m².

> b\. The Dakar Technopole

*Dakar Technopole *

*Dakar Technopole Area Planning and Promotion*

*Professeur Hamet Seydi*

*Head of Mission*

*Tel.: 822 92 48*

58. Since FIAS' last report, no major change has been reported in the
    licensing procedure as a Technopole company, apart from the
    simplification of the licensing procedure which is now done through
    a ministerial order since May 2001 instead of a presidential[^29]
    decree. The delivery of the presidential decree took 3 to 4 months
    while the Technopole Management estimates that the ministerial order
    can be delivered within two weeks though the new system has not yet
    been tested. Application processing does not entail any cost and is
    still the responsibility of the Licensing Committee, which is made
    up of about twelve representatives of various ministries and
    departments. The Committee convenes only when there is a sufficient
    number of applications for consideration.

59. The cost of acquiring a real estate which was one of the attractive
    features of this regime is still advantageous compared to the market
    purchase price of CFAF 8,500/m² and market monthly office rent of
    CFAF 3,500/m².

> c\. Export Processing Free Zone (ZFI)

*Zone Franche Industrielle (Export Processing Free Zone)*

*Amadou Maleine Niang*

*Administrator*

*Tel.: 832 07 84*

60. Since the expiry of the Law on the Dakar Export Processing Free Zone
    in 1999, access to the Zone has been suspended. The companies that
    are still operating in the Zone (7 in all) have benefited from an
    extension of the Law until 2016.

> 2\. Site Layout and Building

*Ministry of Town Planning*

*Dakar Regional Town Planning Department*

*Mr. Mamadou Diene*

*Unit Head*

####### Tel.: 822 20 26

61. No major change has been reported in building permit delivery
    procedure since FIAS' last report. Applications are still submitted
    to the Regional Town Planning Department. Apart from the documents
    listed in the 1999 report, the applicant is also requested to
    deposit a stamped envelop bearing his/her address. The reason behind
    this is to be able to contact applicants in the event of a rejection
    of their applications or when they have to answer additional
    questions. A deposit receipt is issued to applicants pending the
    processing of their applications.

62. Applications are always classified according to their complexity.
    Pink applications are examined internally while green applications
    are sent out for external advice.

63. Green applications are sent out to SPD and LR for verification of
    title to property (in the case of leases, the payment of rents is
    verified) and land boundaries. According to the Regional Town
    Planning Department, the longest delays in application processing
    occur at this stage; applications may be delayed for one to two
    months before being returned to the Town Planning Department. On the
    other hand, consultation with the other departments: Civil
    Protection Department, Public Works Department and Environment
    Department is done simultaneously and does not exceed ten days. It
    is important to note that the advice of the Sanitation Department is
    no longer sought.

64. Based on the favorable recommendations made externally, the
    technical aspects of the application are then examined by the
    internal divisions of the Regional Town Planning Department to
    verify their conformity with the regulations governing the zones and
    compliance with architectural standards. If the internal
    recommendation is favorable, the application is forwarded to the
    town planning unit head for a synthetic recommendation. The internal
    processing of the application takes 10 to 15 days.

65. The application thus reviewed by the Town Planning Department is
    sent to the mayor's office for signing by the mayor. Whereas in the
    provinces, the mayors' offices do not yet have the technical
    capacity to assess building permit applications. The City Hall of
    Dakar operates a technical division with the Urban Planning
    Department (DAU) to evaluate building permit applications. Following
    this second application assessment and if the recommendation is
    favorable[^30], the authorization order is prepared and submitted to
    the city mayor for signing. Before November 2001, the city mayor
    usually sends the order to the district mayor for signing. It often
    took up to three months then to finalize the preparation of the
    authorization order. Since the Special Delegation of the City of
    Dakar assumed the functions of the mayor's office[^31] pending new
    elections, the district mayor's signature is no longer required.

66. On the whole, an investor can spend 2 to 4 months before obtaining
    his/her building permit in the case of a green application. Pink
    applications are processed rapidly. They mainly consist of
    applications for authorization to build on the property of a land
    developer such as the *Banque de l'Habitat du Sénégal* *(Senegal
    Housing Bank)*. In this case, applications are no longer processed
    through the State Property Department and Land Registry. The
    construction plans are signed by the land developer and the
    application is processed only internally over a period of two weeks
    before it is sent to the mayor's office.

67. The associated costs such as the town planning tax (CFAF 5,000) and
    revenue stamp (CFAF 1,000) have also remained unchanged since FIAS'
    last report. On the other hand, while depositing applications with
    the Town Planning Department, applicants now have to pay municipal
    taxes levied by the Town Planning Department on behalf of the
    municipalities. Before the expiry of mayors' mandates in November
    2001, these costs consisted of:

-   CFAF 20,000 payable for all projects; plus

-   CFAF 100,000 for buildings used for industrial, commercial or
    professional purposes.

68. The Special Delegation of the City of Dakar has long cancelled the
    payment of an additional CFAF 100,000 for major building projects;
    it has maintained only the payment of the CFAF 20,000 fee.

69. The procedure and cost associated with the delivery of the
    certificate of conformity following the completion of the building
    work are the same as those identified in the 1999 report. By
    contrast, while the land subdivision application formalities have
    remained unchanged since 1999, the associated costs are clearly
    higher. In fact, from August 2000 up to November 2001, the
    municipalities had instituted a 5% tax on the monetary value of each
    plot with the monetary value rate set at CFAF 20,000 per square
    meter. This translates into a CFAF 10 million tax for a land
    covering 10,000 square meters. However, since November 2001, the
    Special Delegation of the City of Dakar has cancelled this tax and
    replaced it with a less costly system. The tax levied on all land
    subdivision applications consisting of:

-   between 1 to 9 plots, is CFAF 20,000 FCFA per plot;

-   between 10 to 100 plots, is CFAF 15,000 per plot;

-   over 100 plots, is CFAF 10,000 per plot.

> 3\. Impact on the Environment

*Ministry of Environment*

*Environment and Classified Company Department*

*Ndiaye Cheikh Sylla*

*Deputy Director*

*Ernest Dione*

####### Head of Classified Companies

*Tel.: 821 07 25*

70. A new Environment Code (Law 2001-01 dated January, 2001) and its
    application order (order 2001-282 dated April, 2001) were prepared
    in early 2001. the Code retains the factory at risk system, meaning
    plants or companies which, by the nature of their activities, can
    damage the environment. They are always divided into two classes:
    Class One companies that must take preventive measures to ensure
    environment protection before they can start their operations and
    Class Two companies which do not present any serious danger or
    nuisance and must therefore obey general regulations on environment
    protection. Under the new Code, only Class One companies are
    required to apply for prior authorization; Class Two companies are
    only required to declare themselves.

71. Thus, the application processing procedure for Class Two companies
    have been simplified. The documents required for the application are
    the same as previously for these companies. Following site
    inspection within 15 days following the day of submission of
    application, companies receive a declaration receipt from the
    Minister of Environment. According to officials of the Classified
    Company Bureau, the receipt is delivered within a month, but the
    Code allows the Minister of Environment a renewable 2-month period
    to decide on applications (Article R17).

72. The processing of Class One company applications has also been
    changed. Since 1996, the new Code has explicitly taken into
    consideration the transfer of natural resource and environment
    management skills to local authorities.

73. For Class One companies, application components are the same as
    those indicated in FIAS' first report, apart from the impact
    assessment requirement (Article R9). After depositing the
    application, a public inquiry (Article R6 and R7) is launched by the
    Governor of the region concerned. Before it is concluded, the
    inquiry will imply the participation of and advice seeking from not
    less than fifteen personalities or government and municipal
    agencies. It may thus take two months before applications are
    received by the Minister of Environment who may take another one
    month to issue the authorization order.

74. The decision on impact assessment study is itself taken through a
    ministerial order. The study must include a project description in
    relation to its impact on the environment, the corrective measures
    envisaged and their costs. It should be conducted by an engineering
    firm approved according to the methodology indicated by a
    ministerial order. The study is submitted for advice to a Technical
    Committee made up of representatives of ministries and other
    structures concerned by the study under the leadership of the
    Ministry of Environment. The decision of the Committee is forwarded
    to the Minister of Environment who must make his own decision known
    within a month. If the Minister's decision is positive, the
    Chairperson of the Regional Council, the Mayor or the Chairperson of
    the Rural Council must also express their views and are allowed a
    month to do so. A ministerial order is then issued and published in
    the Official Journal.

75. The annual dues and taxes payable by classified plants or companies
    have not been modified since FIAS' last report.

> 4\. Access to Services
>
> a\. Drinking Water

*Water Supply Company (SDE)*

*Mr. Abdulhah Cissé*

*Deputy Director Customer Service*

####### Tel.: 839 37 37

*ONAS (Drainage Company)*

*Mr. Sérigne Mbaye Sy DIOP*

*Director of Drainage*

####### Tel.: 832 35 34

76. Since 1996, the State has separated the drinking water department
    from the drainage and department and delegated, under a
    lease-farming contract, the management of water supply to a private
    company known as *Sénégalaise des Eaux (SdE)*. Drainage was
    entrusted to the *Office National de l'Assainissement de Sénégal
    (ONAS)*, or the Senegal National Drainage Company, a public company.
    Property management and lease-farming contract monitoring were
    retained by a State-owned company, the *Société Nationale des Eaux
    de Sénégal* (SONES) or Senegal National Water Supply Company.

77. ***Sénégalaise des Eaux (SdE).*** For drinking water supply, an
    investor must approach the SdE company. Since 1999, SdE has launched
    a "quality demand" program aimed at reducing waiting time for
    private and company[^32] connections. After submitting his/her
    subscription application[^33], an appointment is set with the
    customer for onsite inspection within ten days. When the quantity
    surveyor arrives on the spot, he/she has ten days to prepare an
    estimate of the work involved. The cost of estimate preparation is
    CFAF 6,000. The customer is still required to pay for estimate
    preparation before he/she can obtain a subscription policy. The cost
    of connections vary according to meter capacity and customer
    location. A new appointment is again set with the customer within
    fifteen days to establish the connection. According to SdE's policy,
    should connections require network extension, the waiting time is
    extended by about ten days.

78. The following Table shows the rates applicable in 2001 to
    individuals and companies.

79. ***Office National de l'Assainissement de Sénégal (ONAS)*** -- For
    traditional[^34] drainage installations, the investor must file a
    connection application, deposit a water bill and pay between CFAF
    200,000 and CFAF 800,000 FCFA according to operation cost. Following
    application submission, a receipt is issued to customer by the
    Management of ONAS, which takes a week to prepare a work estimate.
    According to ONAS, connection is established within a week of paying
    the estimate.

Costs of Drinking Water Consumption

+-------------+----------+------------+----------+----------+---------+
| E           | Customer | C          | P        | All      | Ref     |
| xploitation | Category | onsumption | re-Tax\* | Taxes    | undable |
| Category    |          | Bracket    | Prices   | Incl     | Deposit |
|             |          | (cubic     | (CFAF/   | uded\*\* |         |
|             |          | meter per  | cubic    | Prices   |         |
|             |          | period of  | meter)   | (C       |         |
|             |          | 2 months)  |          | FA/cubic |         |
|             |          |            |          | meter)   |         |
+-------------+----------+------------+----------+----------+---------+
| Cities with | Indi     | from 0 to  | 170.35   | 172.30   | Between |
| Drainage    | viduals, | 20         |          |          | 8,615   |
| and         | 15 mm    |            | 594.22   | 599.42   | and     |
| Sanitation  | meters   | from 21 to |          |          | 35,319  |
|             |          | 40         | 594.22   | 706.38   |         |
|             | Indi     |            |          |          | 158,935 |
|             | viduals, | from 40 to | 681.76   | 809.68   |         |
|             | 20mm     | 100        |          |          |         |
|             | meters   |            | 594.22   | 706.38   |         |
|             | and      | Over 100   |          |          |         |
|             | C        |            | 681.76   | 809.68   |         |
|             | ompanies | from 0 to  |          |          |         |
|             |          | 100        |          |          |         |
|             |          |            |          |          |         |
|             |          | Over 100   |          |          |         |
+-------------+----------+------------+----------+----------+---------+
| Cities      | Indi     | from 0 to  | 170.35   | 172.30   | Between |
| without     | viduals, | 20         |          |          | 8,615   |
| Drainage    | 15mm     |            | 549.90   | 555.10   | and     |
| and         | meters   | from 21 to |          |          | 35,319  |
| Sanitation  |          | 40         | 549.90   | 654.08   |         |
|             | Indi     |            |          |          | 158,935 |
|             | viduals, | from 40 to | 632.40   | 751.43   |         |
|             | 20mm     | 100        |          |          |         |
|             | meters   |            | 549.90   | 654.08   |         |
|             | and      | Over 100   |          |          |         |
|             | C        |            | 632.40   | 751.43   |         |
|             | ompanies | from 0 to  |          |          |         |
|             |          | 100        |          |          |         |
|             |          |            |          |          |         |
|             |          | Over 100   |          |          |         |
+-------------+----------+------------+----------+----------+---------+

\* include dues payable to ONAS.

\*\*include 18 % VAT, hydraulics extra tax and municipal extra tax.
Social brackets (From 0 to 40 cubic meters) are VAT-exempt.

> b\. Power

####### SENELEC

####### Rue Vincens

*Dakar*

*Mr. Kane*

*Subscription Department*

80. Senelec (power supply company): subscription application procedures
    have not changed since FIAS' last report. Even the rate structure is
    still the same. A 10% increase in rates was announced in March 2002
    but the terms for increase distribution among the various categories
    of consumers are yet to be clarified.

81. Senelec argues that connection applications can be met within a week
    if there is already a meter on the location and within three weeks
    if the meter has to be installed by its technical departments.

> c\. Telecommunications

*SONATEL*

*Marketing Department*

*Mr. Boubacar Niang*

####### Unit Head

####### Tel.: 839 23 94

82. Privatized in 1997, Sonatel holds a concession granting it monopoly
    over the provision of fixed telephone service and the establishment
    of international networks until 2004.

83. The telephone subscription application procedure and installation
    costs have remained unchanged since FIAS' last report. The expansion
    of the marketing network across the territory has contributed to
    keeping subscription costs at a fixed level since FIAS' last report.
    In the urban areas, the Pre-VAT costs amount to CFAF 40,000 (and
    43,900 all taxes included) for house connections and CFAF 67,500
    (CFAF 71,400 all taxes included) for company connections. In the
    rural areas, subscription costs are up to four times higher. The
    monthly cost of a standard subscription is CFAF 2,415.

84. According to Sonatel, customers are connected on average within five
    days of receiving their applications. The rate of connections
    effected in less than ten days is 98%.

> d\. Post Office

*Post Office*

*Mr. Papa Demba Mda Ndiaye*

*Department Head*

*Tel. : 849 21 82*

85. Since February 2002, the post office has suspended home mail
    delivery. All residents are required to have a mail address bearing
    a post office box number. Applications for a post office box should
    be filed with the post office using a form that has not changed
    since 1998. In order to encourage users to apply rapidly, the post
    office has instituted a CFAF 100 tax on all mail delivery at home.

86. The new rates for post office boxes are:

\- for individuals: CFAF 9,600/annually in the urban area, CFAF
4,800/annually in the rural area.

\- for associations and professionals: CFAF24,000/annually

\- for companies and administrations: CFAF 48,000/annually

D. OPERATIONAL FORMALITIES

> 1\. Foreign Exchange Control

*Money and Credit Department (MCD)*

*Ministry of Economy, Finance and Planning*

*Mrs. Dieynaba*

*Central Bank of West African States (BCEAO)*

*Dakar Branch*

*B.P. 3159*

*Mr. Abdoulaye Gaye*

*Head of Research Unit*

*Tel. : (221) 823 53 84*

87. No change has been reported in foreign exchange regulation
    since 1998. The only modification was the formalization of this
    regulation by BCEAO through Regulation R09/98/CM/UEMOA dated
    December 20, 1998[^35]. It seems therefore that the problems
    identified in 1998 (prior authorization for down payment and prior
    authorization for direct investment abroad) can no longer be
    resolved at the only level of Senegal. However, FIAS has noted that
    since 1998, the Authorities seem to have developed some de facto
    tolerance towards payment without their prior authorization of down
    payments. Even though this tolerance can but boost business in
    Senegal, it would be preferable, like in the case of tannery
    licensing, as advised in FIAS' 1999 report, to officially regularize
    this situation.

88. Another problem identified in FIAS' 1999 report persists as it
    continues increasing national and non-regional prerogatives: payment
    of a 0.25% tax on all transfers (whether recurrent or capital
    transfers) to countries outside the Franc currency area; this
    requirement is still enforced today. No progress was made in this
    area.

89. On the whole, the waiting times and administrative costs of foreign
    exchange procedures have therefore not been modified apart from
    making the administrative practice in terms of down payments more
    flexible. There are no waiting times associated with recurrent
    operations because the decision-making power regarding down payments
    has been delegated to commercial banks as is practically the case
    today. For capital operations and more specifically investments
    abroad, there are additional waiting times because the prior
    authorization of the Monetary Authorities is necessary and it takes
    about a week to obtain it with the possibility of rejection. As
    stated earlier on, all transfers outside the Franc currency area are
    liable to a non-negligible tax of 0.25%.

> 2\. Importer/Exporter Card

####### External Trade Department 

*Ministry of Trade and Handicraft*

*Rues Leblanc et Emile Zola*

*Dakar*

*Mr. Seck*

*Tel. : 821 57 25*

90. There has been no change in procedure for this formality. The card
    is still an obligation and is issued exactly under the same
    conditions as previously. That is, by subcontracting to a private
    company based in a unit of the External Trade Department. So far, no
    possibility of introducing any flexibility in this obligation is
    contemplated.

91. By contrast, the cost of the card seems to have clearly increased.
    It is now set at CFAF 60,000 compared to about CFAF 16,000 in 1998.
    This cost can be viewed as being very high if one considers that the
    card is required for all import operations whether they are single
    or small ones. On the other hand, waiting times remain very short;
    it is a matter of just a few hours from the submission of
    application.

> 3\. Imports and Exports

######### *Customs Head Office*

*Mr. Camara*

*Director General*

####### Mr. Jean Jacques Nanga

*Director of Research and Legislation*

92. Measures have been taken since 1998 to improve the efficiency of
    customs clearing procedures.

93. It can be noted that automatic data processing is faster with the
    customs data processing system known as GAINDE. In this context, the
    whole data processing equipment was renewed with the introduction of
    a data "mirroring" system aimed at limiting the costs of possible
    disconnections.

94. The IP (Internet Protocol) data transmission protocol has been
    adopted, giving access to a more recent and more performing
    software. The GAINDE processing center, which was affected by
    serious dysfunctions and frequent[^36] disconnections, was moved
    from the port to the most secure site of the Customs Head Office.

95. The fight against corruption within the customs has resulted in the
    reform of staff remuneration system. More specifically, the overtime
    work system (OT), which can represent up to half the average
    remuneration of a staff member, has been modified[^37]. A mechanism
    for sharing OT among all customs officers (and not only among those
    who had direct access to the service for which OT is needed and
    which was once highly coveted) was instituted. Furthermore, OT is
    now paid by forgery-proof coupons that can be purchased directly at
    the Customs Head Office. Another measure taken to fight corruption
    within its departments was the decision to clarify the geographic
    mandate of the different squads whose multiple controls were found
    clearly abusive by the private sector in 1998.

96. Shifting to the WTO customs valuation system using the transaction
    value and not the theoretical value of goods[^38] improved relations
    with the importers. For example, the principle of bill rebate has
    now been accepted by the customs, in accordance with WTO rules.
    Similarly, in the event of persistent disagreement over valuation,
    the customs policy is now to clear the goods in the first place
    provided that an amount equal to the duties calculated on the basis
    of the value advocated by the importer and marked up by 50% is
    deposited with the customs -- the deposit will be regularized once
    the dispute is settled. This practice obeys the principle advocated
    by FIAS that *ex post* controls should be preferred to *ex ante*
    controls.

97. The Imports Verification Program (IVP), which is still in effect,
    has however, been improved since 1998[^39]. When the WTO customs
    valuation principle was adopted, the Customs hired the service of
    Cotecna[^40], whose role was conceived rather as a technical
    assistance provider to the Customs and not as a controller of it.
    For instance, Cotecna assisted the customs in setting up an
    *automatic*[^41] goods selective verification program. The system
    operates on the basis of a fraud risk rating[^42] system taking into
    consideration the importer's history and the type of goods.

98. Lastly, there is an advanced project (being tested at the airport
    for exports) of a complete system of electronic data sharing among
    all participants (transit agents, banks, customs, insurance
    companies, health department, etc). This system known as GAINDE 2000
    is the result of the incorporation of system developments by Trade
    Point[^43] in the customs system.

99. The impact of these various measures seems to have been largely
    positive. On the one hand, the waiting times for customs clearing
    procedure have been reduced to about 3 to 4 days, which marks a
    significant progress compared to 1998 when average waiting times for
    customs clearing were estimated at a *minimum* of one week. This
    progress has been confirmed by both the private sector and external
    trade experts.

100. On the other hand, the many controls seem to have been reduced.
     According to the customs, only 10% of the customs positions would
     now be systematically controlled; recurrent imports for instance
     are reportedly no longer systematically[^44] controlled.

> 4\. Customs Duty Exemption Certificate

*APIX*

*Single Window (Customs)*

####### Mr. Ousseynou Dia

*Senior Customs Inspector*

*Tel. : 849 05 55*

101. No major change is reported apart from the fact that the procedure
     now takes place at the Single Window and not at the Customs Head
     Office.

102. Following licensing under the Investment Code, a number of
     materials and capital goods are exempted from customs duties and
     VAT for a 2-year period. When the operation takes place, the
     licensed company must obtain a customs duty exemption certificate
     from the Chamber of Commerce. The certificate is filled, submitted
     and verified by the customs inspector stationed at APIX. After
     checking its conformity, the certificate is returned to the Single
     Window for transmission to the company (and four copies are
     distributed to the departments concerned). With this signed
     certificate in hand, the company can then go to the customs in
     order to proceed with the actual customs clearing formalities.

> 5\. Domestic Trade

*Domestic Trade Department*

*Ministry of Trade and Handicraft*

####### Tel. : 639 65 59

103. There have been no changes in the texts since 1998 but
     administrative measures are said to have been taken to limit
     discrimination between sale authorization for local goods and
     imported goods. The efficiency of such measures could not be
     verified by the mission.

104. Sale authorization does not entail any financial cost and the
     waiting time associated with the procedure is estimated at a
     minimum of one month because it usually requires the intervention
     of an analytical laboratory.

> 6\. Labor Regulation

*Labor and Social Security Department*

*Ministry of Labor and Employment*

*B.P. 4007*

*Dakar*

####### Tel.: (221) 823 59 08

105. No change has been reported since 1998. The visa requirement for
     "displaced" workers (which is especially meant for expatriates) is
     still maintained. No change has been contemplated so far.

106. There is no financial cost associated with this visa requirement
     and the waiting time for visa delivery is about a week.

> 7\. Tax Clearance

####### Internal revenue Department

####### B.P. 1561

####### Dakar

*Tel.: (221) 823 34 35*

107. Based on the recommendation made in the Plan of Action, the number
     of signatures has been reduced. Today, the only signatures still
     required are those of the Treasury Department and the Internal
     Revenue and State Property Head Office (DGID). The DGID agency
     covering an area is empowered to issue and to sign tax clearance
     applications.

     JMorisset

     /media/pszemraj/PeterTrove/project-files/DATA/ms-word-files/big-DOC/107521.doc

[^1]: Republic of Senegal, Document on the preparation of the private
    sector development strategy

[^2]: See Morisset J and O. Lumenganeso, « Administrative Costs to
    Foreign Investment in Developing Countries », Policy Research
    Working Paper Series, World Bank, May 2002.

[^3]: H. de Soto, The Other Path: The Invisible Revolution in the Third
    World, New-York, Harper-Row, 1999.

[^4]: FIAS, "Senegal: The Investor's Roadmap" December 1998. The survey
    was jointly financed with USAID.

[^5]: Government of Senegal, "Preparation of the Private Sector
    Development Strategy", October 2001.

[^6]: Op. cit, p27.

[^7]: For a deeper analysis of this relation, see. S. Djankov & al. «
    Barriers to Entry », *Quartely Journal of Economics*, February 2002
    or J. Morisset and O. Lumenganeso" Les Barrières administratives à
    l'investissement", World Bank, *Policy Research Working Papers*, May
    2002.

[^8]: Compared to 1998/99, please note that FIAS examined two additional
    procedures (which already existed in 1998). The first one are the
    formalities associated with the establishment of traditional
    enterprises in the category of sectoral licensing. Next, a special
    attention is devoted to the formalities that companies must fulfill
    to make their tax payments.

[^9]: For a more detailed discussion, read Djankov and al.., op. cit.

[^10]: For a detailed description of the tax system and a list of
    recommendations, see FIAS' Report entitled «  Sénégal : Le système
    d'imposition sur les entreprises et les régimes fiscaux », December
    2000.

[^11]: FIAS argued in another report that the current licensing system
    does no longer correspond to best international practices and that
    the direct tax system in force in Senegal should be revisited as
    soon as possible. See FIAS, \"Le Système d'imposition sur les
    entreprises et les régimes fiscaux\", op. cit.

[^12]: For a detailed discussion of these arguments in economic
    literature, see the theory of « public choice theory", for instance
    A. Shleifer, and R. Vishny, "Corruption", *Quarterly Journal of
    Economics*, CVII, p. 599-617, 1993.

[^13]: See. Morisset and Lumenganeso (2002) 10 p. cit.

[^14]: FIAS did not highlight this aspect in its previous survey and
    while assisting the government in the preparation of the Plan of
    Action.

[^15]: Law, n°.91-28 dated April 13, 1991

[^16]: Op.cit.

[^17]: See Article 10 of the April 5th 1995 Decree.

[^18]: Refer to articles 869 & 885 of the Uniform Act relating to
    commercial company and economic interest grouping legislation of the
    OHADA Treaty which governs the legal status of EIG.

[^19]: Senegal Country Framework Report -- World Bank, June 2001.

[^20]: Study Group on Competitiveness and Growth, « Fiscalité,
    incitations fiscales et compétitivité », 2000-2001.

[^21]: Private Sector Development Strategy, op. cit.

[^22]: Private Sector Development Strategy, op. cit.

[^23]: This absence of direct links with the decision center partly
    explains the problems encountered by the economic Policy Unit when
    it was responsible for monitoring the implementation of the plan of
    action. While the Unit possessed the technical expertise to identify
    problems and had established a network of relations with the
    majority of technical committees, its difficulty in sensitizing
    policy makers was a major obstacle to progress in reforms.

[^24]: See decree defining the functions, membership and operating rules
    of the strategic committee for investment promotion (October 16^th^
    , 2001). In this context, it is important that this Council became
    operational as soon as possible.

[^25]: International comparison always has the advantage of further
    motivating national administration.

[^26]: This is the approach suggested earlier herein for the Customs.

[^27]: In the previous system, a bank had to obtain licensing from each
    member country of the WAEMU Area. A bank holding the single license
    must now only see to maintaining a minimum level of working capital
    in each member country of the Area where it operates.

[^28]: Ce sont les articles 869 & 885 de l\'Acte uniforme relatif au
    droit des sociétés commerciales et du groupement d\'intérêt
    économique du traité de l\'OHADA qui régissent le régime juridique
    du GIE.

[^29]: This was one of the recommendation made by FIAS in its first
    report on administrative barriers.

[^30]: DAU happens to return applications to the regional Town Planning
    Department for technical failures.

[^31]: In November 2001, the Special Delegation of the City of Dakar
    took over the functions of the mayor's office up to the organization
    of new elections in May.

[^32]: This initiative does not cover connections of a social nature
    which take more time.

[^33]: Application components have not varied since FIAS' first report.

[^34]: Connections of a social nature are much more cheaper but take
    longer time.

[^35]: Foreign exchange regulation was until that date (post FIAS 1998
    mission) formalized by national texts.

[^36]: These dysfunctions were partly linked to vibrations caused by
    train movements in the vicinity (failure to write on hard disks) and
    a defective power supply.

[^37]: OT is directly paid by importers or their representatives to the
    customs officers according to the type of service provided (For
    example: going to a location).

[^38]: This section is an achievement of the WTO 1994 General Agreement
    which came into effect in 2001 in Senegal.

[^39]: FIAS had suggested that the SGS contract be discontinued.

[^40]: Cotecna Inspection lnc. is a Switzerland-based private inspection
    company.

[^41]: The automatic and even hazardous aspect of the program is
    important to fight customs officers' arbitrariness and hence
    corruption.

[^42]: A grade is granted to signal the potential risk of an operation..

[^43]: FIAS' 1998 report had supported this project which already
    existed at the time within Trade Point. In the meantime, the latter
    benefited from a substantial support from USAID..

[^44]: However, from the information collected by the mission from the
    private sector, all containers reportedly continue being
    systematically escorted by the customs once they get over the
    customs barrier until the effective unpacking of the merchandize.
    Though this aspect does not call into question the progress
    achieved, it suggests, however, that reforms are far from being
    completed.