RESTRICTEDWORLD TRADE
ORGANIZATIONG/SCM/W/484
7 February 2002
(02-0596)
Committee on Subsidies
and Countervailing MeasuresOriginal:  English
MEMBERS' DIFFICULTIES IN MAKING SUBSIDY NOTIFICATIONS,
AND THE PLANNED SUBSIDY NOTIFICATION SEMINAR
Reply to Questions in document G/SCM/W/473
of 18 December 2001
Paper Submitted by Dominica
The following communication, dated 5 February 2002, has been received from the Permanent
Representative of the Commonwealth of Dominica.
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B. QUESTIONS CONCERNING DIFFICULTIES IN NOTIFYING
Q1. Does your government face resource constraints in trying to make subsidy notifications?
If so, what are the major bottlenecks in the notification system of your government?  Is the
problem primarily an insufficient number  of staff to handle the notifications, or is it more a
question of insufficiently trained  staff?
Reply
In meeting its notification requirements Dominica faces resource constraints in both the form
of insufficient staff and insufficiently trained staff.  Only one individual in the Ministry of Trade has
had some training on the WTO Agreements and the notifications required.  Given that the Agreements
cover all the sectors of the economy there is need for training in the other Ministries of Government
(particularly the Ministry of Agriculture) for staff who would be able to prepare notifications in theirrespective area.
Q2. Depending on your answer to question 1, above, if the notification questionnaire format
could be simplified, would this make a diff erence to your government’s ability to make the
required subsidy notifications?
Reply
Complexity in the format of the questionnaire is not the main problem in Dominica's fulfilling
its notification requirement for subsidies.
Q3. Balancing your government’s needs for as simp le a format as possible against its needs
to be able to understand other Members’ notifications when it reviews them, how much
simplification could be introduced without sacrificing transparency?G/SCM/W/484
Page 2
Reply
See 2 above.
Q4. Considering the notification format itself, and the concepts underlying it as found in
SCM Articles 1-3, in your government’ s experience, do individuals responsible for making
notifications have difficulties understanding the requirements due to the language used in the
Agreement to define “subsidy”, “specificity”, etc. ?  For example, do these individuals believe
that subsidies are in the nature of cash grants  only, and do not encompass revenue foregone via
tax and duty incentives?  Could some sort of explanation be introduced into the questionnaire
format to make more clear the scope of measures that are subject to notification?  How might
such an explanation be worded?
Reply
The Ministry under which subsidy programmes in Dominica falls and thus which is
responsible for preparing the subsidies notification lacks the training to provide an understanding ofthe concepts found in the Agreement.  Some sort of explanation could be introduced to make the
process easier.  This explanation could take the form of a definition of terms with clear examples.  For
example in the definition of a subsidy (including definition specificity and benefit conferred) an
illustrative list could be given.
Q5. Does your government experience general pr oblems due to the formatting requirements
of the notification questionnaire?  In particular, does your government maintain any pre-
existing information that addresses the substance of the notification questionnaire, but does not
correspond to the questionnaire’s format?  If so, what are the specific problems that your
government encounters when it tries to fo rmat the information as required by the
questionnaire?  If the information were to be notified in its pre-existing format, could it
nevertheless be keyed to the data elements of the subsidy questionnaire?
Reply
A main problem encountered has to do with questions 6 and 7 of the questionnaire.  The
requirement that information be provided on subsidies per unit is difficult to meet.  Dominica'sprinciple form of subsidy is fiscal incentives.  Data/statistics are not kept on the monetary amount of
the subsidy per year and per unit.  This would involve calculating/estimating the foregone import
duties and income taxes per product/company/industry/sector (what is the unit?) per year.  This could
be a very involved task particularly where income taxes are concerned.
Q6. In reviewing other Members’ notifications, would your government find it problematic
to review information that was formatted in a way other than the way foreseen in the subsidy
questionnaire, but that comprehensively ad dressed the substantive elements of the
questionnaire?  How important would it be for this information to be keyed or coded to the
questionnaire format?
Reply
Dominica's limited human resources and capacity has not allowed it to review other countries
subsidy notifications.
Q7. Does your government maintain any info rmation about its subsidy or incentive
programmes on official web sites?  How much wo uld your notification of subsidies be simplified
if such information could be submitted in its pre-existing format?  As a reviewer ofG/SCM/W/484
Page 3
notifications, what sorts of limits should there be to the substitution of information from web
sites for completed notification questionnaires?  Would references to web sites be a useful
supplement to substantive information provided in a notification?
Reply
Dominica maintains no information on subsidy on a website.
Q8. Concerning General Rule 6, which requires that  notification of subsidies provided “to
specific products or sectors” be organized on a product- or sector-specific basis, does this rule
pose problems for your government when notifying subsidies that are provided on a horizontal,
rather than a product- or sector-specific basis?   What are the specific steps and difficulties in
preparing sector- or product-specific informatio n for subsidies provided on a horizontal basis?
Reply
See response to 5 above.
Q9. Does this rule present problems for notifi cation of subsidies that are provided on a
product- or sector-specific basis (e.g., some agricultural subsidies)?
Reply
Dominica provides no product- or sector specific subsidies.
Q10. Would a redrafting of General Rule 6 to refer to subsidies "provided on the basis of
specific products or sectors" help to resolve this  problem?  (The idea would be to clarify that
programme-based information, rather than product- or sector-specific information would be
required for subsidies provided on a horizontal basis, which product- or sector-specific
subsidies would continue to need to be notified on that basis.)
Reply
Yes. Such a redrafting of general rule 6 would help to the extent that a different notification
would not have to be prepared for each product/sector for the same programme.
Q11. Would such a redrafting pose problems for the review of subsidy notifications, and if so,
what would those problems be?
Reply
See 6 above.
Q12. To what extent does the general requirement to provide statistical information on the
trade effects of notified subsidies (chapeau of  item 9) impede or delay the presentation of
subsidy notifications?
Reply
Statistics on production and consumption are very difficult to provide, as these are not
regularly compiled.G/SCM/W/484
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Q13. To what extent does the need to compile the specific kinds of statistical information
referred to in items 9(a) and 9(b) impede or delay the presentation of subsidy notifications?
Reply
See 12 above.
Q14. How important is this statistical informat ion about other Members’  subsidies to your
government when reviewing subsidy notificati ons?  Could these reporting requirements be
made less stringent in some manner?  If so, how?
Reply
See 6 above.
Q15. Does your government find, in preparing s ubsidy notifications, that there is conceptual
overlap or redundancy in some of the information elements as currently drafted?
Reply
Questions 5 and 6 would seem to provide the same information.
Q16. If your government believes there to be overlap, how might this be eliminated?  What
drafting improvements might be introduced to clarify such situations, while preserving the
substantive requirements of Article 25 from which the questionnaire is drawn?
Reply
Questions 5 and 6 could be merged.
Q17. Do the requirements to provide information on the policy objective or purpose of the
subsidy, its background and authority, and to whom and how it is provided pose significant
difficulties to your government in preparing its subsidy notifications?  How might these
requirements be simplified?
Reply
This aspect is not a major difficulty.
Q18. Does the requirement to furnish an explanation where a particular element of
information cannot be provided pose particular difficulties to your government in preparing its
notifications?  If so, is there a way to simplify this requirement while preserving its substantive
content?
Reply
This has not posed a difficulty.
Q19. Is there sufficient flexibility in item 7 of the subsidy questionnaire (information on the
amounts of subsidies provided) for your government to be able to notify such information
without undue difficulty?  If not, is there a way to simplify this requirement while preserving its
substantive content?G/SCM/W/484
Page 5
Reply
The principle difficulty is in preparing the information as a result of the unavailability of
ready data and statistics.  The need to preserve the substantive content of the requirement (i.e. the
amount of the subsidy as precisely as possible) must be maintained.  For a country like Dominicawhat is needed is technical assistance in developing and maintaining the information and statistics that
will enable us to provide this information not only for WTO notifications but also for our own policy
development and review.
C. 
QUESTIONS PERTAINING TO THE SUBSIDY NOTIFICATION SEMINAR
Q1. Concerning the number and nature of pa rticipants in the seminar, how many
individuals in your government have day-to-day responsibility for gathering information about
subsidies and for preparing and submitting subsidy notifications based on that information?  If
more than one, please describe the differen ces in these individuals ’ responsibilities.
Reply
Currently only one individual within the Ministry of Trade has that responsibility.
Q2. Would it be sufficient for your government to have two participants in the seminar?  If
not, why not, and how many participants would be optimal from your government’s point of
view?
Reply
It would be sufficient.
Q3. Would two days be a sufficient/appropriate length for the seminar?  If not, what would
be more appropriate?
Reply
Two days sounds just about right.
Q4. Would the following schedule be appropriate:  First session:  detailed presentation of the
basic definitions in Articles 1, 2 and 3 of the SCM Agreement, and presentation of the subsidy
notification obligations in the light of these definitions.  Second session:  Presentations by
Members concerning the specific problems they experience in preparing subsidy notifications.
Third session:  Information-sharing and brainstorming among Members as to possible practical
solutions for the identified problems (ways to coordinate and streamline gathering and
formatting of subsidy information).  Fourth session:  Follow-up steps to ensure that information
shared and lessons learned would be retained and implemented.  (It has been emphasized thatto be effective, such follow-up should be immediate and intensive.)  Ideas suggested to date have
included establishment of informal contacts am ong capital-based officials, planning of future
focused technical assistance activities, etc.
Reply
Session one would need to encompass a significant part of the time to allow a fairly detailed
presentation on the notification requir ements with practical examples.G/SCM/W/484
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Q5. Does your government normally send capital-based representatives to the Committee’s
regular meetings?  If not, why not?
Reply
No.  The cost is prohibitive.
Q6. Does your government view this subsidy noti fication seminar as an important event in
improving its ability to understand the subsidy rules, and to make subsidy notifications in a
complete and timely manner?  (That is, does your government view the seminar as a priority
event for its participation?)  Does your government  plan to send capital-based participants to
the seminar?  If so, how many and what are their functions?  If not, why not?
Reply
Dominica views this as an important event an d would want to attend.  However self-funding
participation of capital based officials would make that not possible.
Q7. In the view of your government, would financial sponsorship only of participants from
least-developed country Members be appropriate?  If not, why not?  What other objective
criteria for eligibility for financial sponsorship could be developed that might be more
appropriate?
Reply
Sponsorship would need to include small developing countries such as Dominica.
Q8. If your government would be prevented from sending participants to the seminar due to
financial constraints, what is the minimum level of financial sponsorship that would make it
possible to send participants (e.g., airfare only, airfare and subsistence for the days in Geneva,
etc.)?
Reply
The minimum level of sponsorship would have to be airfare and hotel.
Q9. Assuming that it is not possible to finance the seminar out of existing trust funds in the
WTO (a possibility currently being explored), and assuming a total budget of approximately
CHF 225,000, would your government consider making  a donation to finance it?  If so, how
much would your government be in a position to contribute?
Reply
Dominica would not be in a position to make a financial donation.G/SCM/W/484
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Q10. If the seminar were financed by earmarked contributions from individual Members,
and there were a surplus in the budget for the seminar (due to fewer than expected participants
from Members eligible for financial sponsorship,  however they might be identified), how should
any such surplus be disposed of?  Two possible  options have been discussed (i) returning the
surplus to the sponsors on a pro-rata basis; or (ii) making the surplus available on a first-come,
first-served basis to other developing countr y Members.  Are there other, more appropriate,
options?
Reply
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