RESTRICTEDWORLD TRADE
ORGANIZATIONG/SCM/W/493
14 February 2002
(02-0753)
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 Turkey
The following communication, dated 12 February 2002, has been received from the
Permanent Mission of Turkey.
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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
Turkey has no major constraints in trying to make subsidy notifications.  However,
availability of only a limited number of sufficiently trained and experienced technical staff may
occasionally pose problems for making subsidy notifications on time.
Q2. Depending on your answer to question 1, above, if the notification questionnaire format
could be simplified, would this make a difference to your government’s ability to make the
required subsidy notifications?
Reply
It is doubtless that a more simplified format may encourage countries in fulfilling their
notification obligations.  However, since the format itself is not a sole source of problems countries
face, there may still remain some other challenges heavily depending on insufficient technical
capacity.  On the other hand, it is our concern that a simplified format may not be sufficient to
describe national legislation in a satisfactory way.
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/493
Page 2
Reply
Considering that a full notification is going to be done once every two years, it might be
better not to oversimplify the notification format, since it may result in some misunderstandings for
the third countries.  Consequently, simplification of notifications should be made to the extent that itdoes not bring about any lack of information or confusion.
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 questionnaireformat to make more clear the scope of measures that are subject to notification?  How might
such an explanation be worded?
Reply
The definitions of terms in the Agreement on Subsidies and Countervailing Measures (SCM)
are clear.  However, regarding item 7 of the SC M Questionnaire, some problems are faced with the
measuring of subsidy per unit in our export credit, guarantee and insurance programmes, leading us to
omit this item in our notification.  Consequently, further clarification on this issue will be helpful.
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
We do not experience general problems due to the formatting requirements of the notification
questionnaire.  On the other hand, it is believed that allowing a "free form" style in order to be able todescribe and explain how Members' systems work will be useful for more transparency (a web pages
link on the WTO page can be easily used for this purpose).
For certain types and forms of subsidies or incentives, it is possible to bring about immediate
data results;  but for many other types of incentives, especially one's that effect trade indirectly and in
due time, it will not always be possible to show immediate data results and verify their specific trade
effects.  For this reason, it might be better to allow for a section in the questionnaire where thecountries will have a "free-form" section to describe the details.
In many countries we see specific, pure and simple "point and shoot" type of subsidies and
these are handled in the simple approach within the present format.  But, more "in detail" issues which
have not been previously realized come out only when evaluated reviews are done.
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?G/SCM/W/493
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Reply
Although notifications prepared within the existing format are preferred, ones that are not in
total compliance with the framework of the format are acceptable, only if substantive elements of thequestionnaire are comprehensively addressed.  However, in order to make other members review the
notifications in an easier way, Members should try to prepare their notifications in that format.
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 of
notifications, what sorts of limits should there be to the substitution of information from websites for completed notification questionnaires?  Would references to web sites be a useful
supplement to substantive information provided in a notification?
Reply
An official we site (www.treasury.gov.tr) related to incentives for investments and
implementation programmes of Turkey is available on the internet.  Additionally, Turk Eximbank's
export credit, export credit insurance and guarantee programmes will be available on the web site,
which is www.eximbank.gov.tr in the very near future.  To the extent that time and budgetary
opportunities allow, it would be much simpler to use the web pages of other countries, as long as the
documents involved are official.
It is believed that there need not be any limits for the substitution of certain information from
referred web sites.  It can be a simple idea to create a link page under the WTO-SCM page, showing
all the official link addresses of countries which maintain related pages.
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?
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)?
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.)
Q11. Would such a redrafting pose problems for the review of subsidy notifications, and if so,
what would those problems be?
Reply
Non-availability of statistical data permitting to address the trade effects of the subsidies,
including export subsidy programmes for agricultural products and export credit, export credit
insurance and guarantee programmes may pose problems to provide information on product or on a
sector specific basis.G/SCM/W/493
Page 4
In this regard, redrafting of General Rule 6 might simplify the problems challenged.
However, since how the system works will heavily depend on countries' individual conditions, that
may be helpful only to a small extent.
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
In some cases, it can not be possible to calculate the trade effects immediately.  In practice,
some subsidies' effects can only be felt in the long run that may result in delays in fulfillingnotification obligations.
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
To compile the statistical information referred to in items 9(a) and 9(b) does not impede or
delay the presentation of subsidy notifications.
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
The statistical information provided on the subsidy implementations of other Members is a
beneficial instrument for countries in reviewing notifications.  As it is pointed out in the previous
question, concrete definition on the trade effects would be helpful to sufficiently evaluate provided
data.
Regarding incentives for investments and implementation programmes, elementary
information such as inflationary rates, relative cr edit rates of a country in question is important in
evaluating the situation clearly.  It is believed that this kind of information can help draw conclusions
on the effects of the subsidies provided on the rest of the markets.
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
No.
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?
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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 significantG/SCM/W/493
Page 5
difficulties to your government in preparing its subsidy notifications?  How might these
requirements be simplified?
Reply
We have no specific problems to provide information on the policy objective or the purpose
of the subsidy.  However, with regard to genera l programmes in which implementation issues are
more diversified, answering to whom subsidies are provided becomes difficult since the questions are
mostly designed to satisfy specific cases.
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 itsnotifications?  If so, is there a way to simplify this requirement while preserving its substantive
content?
Reply
No.
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 itssubstantive content?
Reply
As previously underlined, difficulties with the definition of the subsidy per unit for the
officially supported export credits.  We need further clarification in this regard.
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
Due to the fact that, the programmes we notify are under the responsibility of various
government agencies, as Undersecretariat of Foreign Trade, Undersecretariat of Treasury and TurkEximbank, not only one person is individually re sponsible, but a couple of people share the
responsibility of gathering information, formatting and submitting Turkey's subsidy notifications.
Moreover, the relevant officials are not in charge of WTO issues but also other international
organizations and agreements.
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?G/SCM/W/493
Page 6
Reply
In Turkey, there are several authorities dealing with export subsidies and investment's
incentives and implementation programmes as mentioned above.  Therefore 5-6 participants will be
optimal for us.
Q3. Would two days be a sufficient/appropriate length for the seminar?  If not, what would
be more appropriate?
Reply
The schedule offered is fine.  However two days does not really seem realistic for such a large
group with such a schedule.  Expanding the duration of the proposed seminar to 3 or 4 days will be
much more useful.
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 that
to 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
The proposed schedule is acceptable.  However, as previously emphasized a two-day seminar
may not be sufficient to create expected benefits.  For this reason, with a view to providing for a more
active and effective participation, a four-day seminar, allowing for a session each day is considered to
be more realistic.  As for the method to be foll owed during the seminar, the last two days can be
specifically devoted to addressing the problems faced with making subsidy notifications.
Q5. Does your government normally send capital-based representatives to the Committee’s
regular meetings?  If not, why not?
Reply
As long as possible, committee meetings are regularly followed by capital-based
representatives.  However, the meetings in which some technical information is much more needed
have priority.
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?G/SCM/W/493
Page 7
Reply
We do not have problems in submitting our subsidy notification.  But if further clarifications
are made in the notification format, we believe that it would help Members to review others'
notifications in a more efficient way.  For that reason, this seminar is important for our governmentand we are planning to send capital-based representatives.
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?
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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.)?
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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 approximatelyCHF 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
We are not in a position to contribute.
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?
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