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This study describes the challenges faced by customs officials in the
Philippines when they adopted transaction valuation to facilitate imports,
and the way in which they overcame these challenges. The Philippines
government needed to adopt its international treaty obligations into
domestic law, and it did that with two laws. It enacted Republic Act (RA) 8181 in 1997, which enabled transaction valuation reform. However, various
obstacles hindered the implementation of this law, and so in 2001 the
government adopted RA 9135 to fix the problem in RA 8181 so as to
authorize post-entry audit systems.
There had been two major concerns in the Philippines regarding the country’s
obligations to shift its customs values from notional published values to
transaction values. On the part of the customs authorities, they expected
customs collection to go down as importers took advantage of their legal
rights, undervalued their imports with fake invoices knowing that customs
authorities would never know on time that they did so and so paid lower
duties and taxes than they ought to. On their part, domestic producers
were fearful that implementation of this obligation would erode their
trade protection. The Philippines has nevertheless implemented its
obligation and has used transaction values in customs assessments since
2000.
Three and a half year later, the then Customs Commissioner, Antonio M.
Bernardo, has been pleased to see that customs collections have been going
up. However, domestic producers are still concerned and keep adjusting to
these changes. This study documents the policy reform process, assesses
the impact of the reform and highlights the tasks yet to be done to
implement transaction valuation reform effectively and properly.
I. Why reform customs valuation? back to top
In 1996, when the Philippines enacted RA 8181, its customs valuation
procedures deserved a major overhaul, at least from the perspective of
reducing corruption and facilitating trade. Its pre-reform rules
virtually allowed customs authorities to exercise wide discretion and
compel importers to make deals with customs authorities to secure the
most privately profitable terms for their businesses, in particular
because of high tariff protection. Multiple customs valuation rules had
been a tradition since RA 1937 in 1958, when customs authorities could
legally calculate duties and tax assessments based on wholesale prices
in exporting countries, with domestic prices adjusted appropriately to
make these comparable to border prices or invoice values. That was
because the law failed to specify when a particular rule should be
employed. Because it also prescribed high tariff protection in order to
protect domestic industries, RA 1937 sowed the seeds of corruption in
customs administration in the Philippines.
The reforms following RA 1937 aimed at undoing the abuses of customs
officials. Since 1972 there have been efforts made to publish home
consumption values, defined to be the wholesale price of the good at
about the time of exportation from the principal markets of the
exporting country, and to delegate to the Philippine consular office
staff the task of gathering data on home consumption values (HCV) and
certifying the authenticity of these values. The list of published
values failed to halt the problem because the values were not updated
with the market, only 20% of the imported merchandise had published
values, and only 10% had correct home consumption values.(1)
Although importers could obtain consular certification of the
authenticity of values to spare them the extra cost of an outdated and
incomplete list of published values, this remedy nonetheless continued
the regime of virtually multiple valuation rules, increased business
transaction costs with the customs agency, and possibly spread the
integrity problem rooted in customs administration to consular offices.
The next initiative came in March 1987, when through Executive Order
(EO) 186, customs authorities used fair market values, which were
defined as the wholesale price of the merchandise being exported to the
Philippines in the principal market of the exporting country at the time
of exportation or, in the absence of that information, that of a similar
good being sold in the Philippines. The EO also ordered the use of the
actual cost of freight and insurance instead of an across-the-board 10%
surcharge to cover such costs and incorporate other expenses needed to
bring the goods to the Philippines to obtain the dutiable value. The
Bureau of Customs continued to maintain a list of published values of
HCVs, but stopped making consular officials responsible for customs
administration functions.
With hardly any resulting improvement, EO 186 had to be complemented
by a pre-shipment inspection (PSI) requirement to authenticate the
declared values of imported merchandise. In 1987 the government
contracted the services of the Swiss-based Société Générale de
Surveillance (SGS) to do pre-shipment inspections for imported
merchandise with a value of at least US$500 coming from Japan, Hong Kong
and Taiwan. The SGS issued a Clean Report of Findings (CRF) to the
Bureau of Customs, which indicated the validated dutiable value after
conducting an inspection in the exporting country. The coverage of the
SGS pre-shipment inspection contract was extended to all countries and
all imported merchandise in 1992.
Although PSI was generally regarded as a protection against the
abuses of customs officials, the Philippines was not getting value for
the 2 to 3 billion pesos a year it spent on this contract, say PSI
critics, who remained unconvinced of the company’s contribution to
customs collection. Thus, in April 2000, when the Philippines had to
implement RA 8181, the government decided not to renew the contract with
SGS and stopped PSI altogether.
What was seen as the promising reform needed to weed out corruption
and reduce business transaction costs with the customs agency, was to
implement the WTO’s transaction valuation rules. As a founding member
of the WTO, the government planned to adopt the rules into its domestic
law. The rules require members to use transaction value in customs
assessments, which is defined as the price actually paid or payable for
the goods when sold for export to the territory of the importing
country. Besides the invoice value, transaction value covers as well
brokerage fees, cost of containers, packing, cross-border transportation
including loading, unloading and handling charges, and the cost of
insurance. Expenses which may not be reflected in the invoice but are
generically part of the cost of making the goods available to the
consumers in the importing country include commissions, royalties and
licence fees. These are counted as part of the transaction value of the
merchandise. The positive point regarding these rules is their
anticipation of the likely situations when computing transaction values.
The rules prescribe six methods of computing transaction values and the
conditions for using each method.
II. RA 8181: a good attempt given the constraints back to top
When the Philippines government incorporated into domestic law its
legal obligations under the WTO’s transaction valuation agreement in
1996, the political atmosphere in the country was become increasingly
hostile to WTO compliance laws. To give legal weight to these
obligations only served to sustain the confrontation between those
against globalization and those behind the integration of the economy
into the global trading system.(2)
The chairman of the Ways and Means Committee of the Senate in 1996,
Senator Juan Ponce Enrile, assumed the primary task of shepherding the
bill on transaction valuation through the eleventh Congress. The House
of Representatives had approved House Bill (HB) 3946 on transaction
valuation reform and passed this on to the Senate for its consideration.
The timing of this bill was good. The congressional leadership at that
time and then President Fidel Ramos fully backed its authors. After all,
compliance with the country’s WTO obligations was the order of the day
for all developing country members of the WTO.
Senator Enrile had previously served as Commissioner of Customs in
the government of former President Ferdinand Marcos. As with all customs
commissioners, he focused on increasing customs collection by reducing
technical smuggling and corruption. Reportedly, Marcos had personally
asked him to take the Commissioner’s post when customs collection was
seriously declining in the 1970s. He knew how tax evaders and corrupt
officials worked and that there was still a good number of them in the
country and at the Bureau of Customs. Thus he was convinced that the
proposed transaction valuation reform had to have a safeguard to assure
successful reform.
The action taken by the Senate was to retain the use of published
values to deter undervaluation, even as transaction values were ordered
to be used for customs valuation purposes starting in 2000. The use of
published values per se is in compliance with the WTO’s transaction
valuation rules, if the prices published are transaction values at the
time the merchandise is imported. In the Philippines, however, the
published values were home consumption values, not updated in line with
the market,(3) neither were the data comprehensive enough to cover all
possible imported merchandise. Thus it was likely that the use of
published values as ordered in RA 8181 would be inconsistent with
transaction valuation rules.
The Bureau of Customs officials in 1997 had pointed to the likely
legal problem of including in RA 8181 the use of published values and
the likely implications for customs administration in having two
valuation rules. The chairman of the Ways and Means Committee in the
Senate appreciated this concern and asked customs officials to suggest
an alternative safeguard. Since the officials were unable to propose any
at that time RA 8181 was approved including published values.
Adjusting import assessment procedures
back to top
The customs agency adjusted its import assessment system to implement
RA 8181. Pre-shipment inspection had to go, customs officials having
concluded that retaining the PSI for valuation purposes would only
create problems; they decided not to extend their PSI contract with SGS.
The Commissioner, however, extended SGS services for three months or
until 31 March 2000 to give the bureau the opportunity to master the new
systems and procedures under RA 8181. There would be shipments in those
three months that would continue to be processed using the PSI system
and others that would then be covered by the customs orders implementing
RA 8181.(4)
The value range information system (VRIS) was introduced to deter
attempts to undervalue imported merchandise. The system consists of a
database giving high and low transaction values of the merchandise
imported in commercial quantities to the Philippines. If the declared
value of a given shipment falls outside the range, the importer would
have to show the relevant documents to the Valuation and Classification
Review Committee (VCRC) to support his declared value. According to
Philippines customs authorities, Article 17 of the WTO Customs Valuation
Agreement allows the use of the VRIS for validation purposes. If the
documents presented failed to remove reasonable doubt, the importer
would need to post a bond to support the conditional release of the
shipment.
As SGS’s PSI contract ended in March 2001, the Super Green Lane (SGL)
facility became operational. The SGL is a facility meant for regular
importers, most of whom were concerned about harassment in the post-PSI
import processing system. To use this facility, an importer would need
to be accredited by the bureau as a low-risk importer. In theory, the
SGL goods require only an hour to process, and processing simply
involves the matching of payment of duties and taxes with assessment.
SGL merchandise does not go through the bureau’s selection system.
Examination of goods may be conducted at random and at the premises of
the importer. SGL importers are subject to post-release audit, the
purpose of which is to verify whether their import activities are in
accord with the bureau’s and other government agencies’ regulations
and to help these importers improve compliance.
RA 8181 had two valuation rules: published official and transaction
values. If they differed, customs authorities chose the higher of the
two.(5)
III. RA 9135: improving the law
back to top
The Philippines customs officials realized
that using published values as laid down in RA 8181 would only
complicate customs administration. However, they needed a proposed
alternative to published values before they went back to Congress to ask
for an amendment of the law. When the chairman of the Senate Ways and
Means Committee asked them for an alternative to published values to
assure revenues, the customs officials were not ready with a good
answer. They had heard about customs audits from training programmes
sponsored by the Asia Pacific Economic Co-operation council (APEC) and
executed by individual governments, but did not know how the audits were
carried out in the countries that used them.
The Bureau of Customs took a political gamble
in asking Congress to amend the law by removing the use of published
values and giving the bureau the power to undertake customs audits.
There were those who advised customs officials to fix the problem of RA
8181 with appropriate regulations and not ask Congress for an amendment.
However, the customs officials thought they could win the amendment they
sought for, having gone through the implementation issues with respect
to RA 8181 and improved their understanding on the concept and
operational aspects of post-entry audits.(6)
Post-entry audit: a licence to abuse?
back to top
In late August 1999 the House of
Representatives Ways and Means Committee, then chaired by Representative
Danilo Suarez, held its first public hearing on HB 8011, supported by
the Bureau of Customs, seeking to amend RA 8181.(7)
In this bill, the customs authorities sought to replace published values
with post-entry audits to assure revenues. Before RA 9135 became law in
2001, customs authorities did not release goods to their owners until
they had determined that such goods complied with the customs code of
the Philippines, the implementing regulations thereof and relevant
regulations of other government agencies. The transaction valuation
rules of the WTO, however, conferred legal rights on importers with
respect to valuation. The declared transaction value, supported
appropriately, is the dutiable value, unless the customs authorities
have evidence to the contrary. This then implied a paradigm shift in
customs supervision from front-end to back-end control, which
facilitates trade. Post-entry customs audit is the primary tool of the
latter approach.
The Chamber of Customs Brokers, headed by
Leonides David, supported HB 8011 but opposed a provision related to
post-entry audit obliging his members to keep import records for five
years and assigning penalties for failure to do so. David pointed out to
the committee that although brokers were in possession of authenticated
copies of original import documents, they could not ascertain whether
the document they processed contained truthful declarations by their
importer-clients.
David’s concern was typical of the private
sector’s general discomfort with the Bureau of Customs’ proposed
audit powers. With a negative perception of tax audits as carried out by
internal revenue auditors and of the integrity of customs officials,
importers saw in customs audits opportunities for abuse, harassment and
corruption at their expense.
Members of the committee expressed
reservations about a possible abuse of the power to audit.
Representative Bueser, a committee member, sought to limit the proposed
audit powers of the bureau. Representative Jesli Lapuz, a co-author of
HB 8011, leaned towards limiting these powers to ‘questionable imports’,
which the then Deputy Customs Commissioner Villanueva said could amount
to as much as 10% of total imports, and towards reducing the legally
prescribed period during which import transactions could be audited.
Lapuz declared that the bill should be worded to allay fears that the
shift to transaction values meant that importers and brokers would have
to be alert for five years waiting for a possible audit by the bureau.
Representative Suarez preferred the use of compulsory acquisition to
deter undervaluation but remained open to the idea of audits.(8)
The brokers’ association disagreed with compulsory acquisition, saying
that this would dampen trading.
These concerns significantly shaped the plans
as to how the bureau intended to implement custom audits. Those to be
audited, said Villanueva, would be selected following the risk selection
criteria that the Department of Finance would have to approve and the
bureau would implement using information technology and in a manner that
was transparent. The selection of those to be audited and the
preparation of the audit agenda covering the audit issues that needed to
be raised during a field audit would be undertaken by a different unit
from that of field auditors. The bureau requested an additional
appropriation to upgrade its computer system. The prescriptive audit
period was reduced from five to three years, but the brokers failed to
get an exemption. Villanueva declared that the bureau was ready to let
pre-shipment inspection go and instead use post-entry audit. In the
fourth and final public hearing of the committee,(9)
the bill’s co-author, Representative Herminio G. Teves, assured the
committee that the post-entry audit was a compliance assistance and
revenue assurance measure.
‘Going beyond our commitment’
back to top
Amending RA 8181 was ‘going beyond our
commitment’, said Bernardo Mitra, representing the Petro-chemical
Manufacturers Association of the Philippines (PMAP) during the second
public hearing by the Senate Ways and Means Committee.(10)
The leaders of a few domestic producer groups, such as Joseph Francia of
the Federation of Philippine Industries (FPI), went as far as to ask for
a postponement of the implementation of even RA 8181, because the
government, he asserted, was not ready. The FPI was concerned about
giving a legal right to importers with respect to value declaration when
the government was not prepared to prevent undervaluation and did not
have an equivalent substitute to pre-shipment inspection. FPI members
were concerned about the erosion of trade protection which transaction
valuation rules, he believed, would induce.(11)
During the Senate public hearing
representatives of domestic producer groups made their case that RA 8181
was better because it incorporated the government’s standard on
valuation with published values. If customs authorities wanted
post-entry audit powers, then the bill ought to have this as its sole
purpose and not amend RA 8181. They took issue with the six methods of
determining customs values, which, they said, widened the discretionary
powers of customs officials.
The need to improve RA 8181
back to top
The prevailing message at the Senate hearing
was that while RA 8181 enabled transaction valuation, it had to be
improved in order to reduce discretion, make valuation more transparent
and provide the customs authorities with a post-entry audit system to
improve compliance and assure revenues. Rey Nicolas, a customs
collector, explained that the six methods were alternate, exclusionary
and hierarchical methods, and that the proposed bill in fact limited
discretion by making the law more systematic and clear on when and on
what to use each method. Senator Enrile, answering a representative of
the PMAP, said that the Senate wanted to improve RA 8181. If declared
transaction values were truthful, no problem would arise. However, if
mistakes occurred, the post-entry audit process would sort these out and
help importers improve their compliance in subsequent import
transactions.
President Arroyo signed RA 9135 into law on 28
April 2001. Besides enabling transaction valuation in the Philippines,
this Act is more transparent and more compliant with the WTO customs
valuation agreement, removes unnecessary discretion and assures revenues
more positively than does RA 8181.
IV. Transaction
valuation reform: an assessment(12)
back to top
The effect on customs collection
With these reforms in place, customs revenues
appeared to increase and not fall, as had been expected. Ex ante
studies on the relationship of transaction values and revenues observed
that customs revenues would decline from 3.95%to 6.5%.(13)
With customs collection accounting for 20% of the government’s income
from taxes, the customs authorities had been concerned about
undervaluation and what this would do to their collection.
Using the data on collection relating to the
three major ports of the country (Port of Manila, Manila International
Container Port and Ninoy Aquino International Port) for the period
before and after the implementation of the reform (1998-2001), the ex
post facto effect of transaction valuation on revenues indicates
revenue gains of about 3.7 billion pesos or 2.6% of the 2000-01
collection of the three ports. The analysis suggests that the
transaction valuation reform brought down the unit values of imports,
which then expanded the base of import tariffs and border taxes. The
results suggest that the use of home consumption values ostensibly to
preserve, if not increase, tax incomes, ironically appeared to moderate
any increase in tax collection at the border, if not reduce it, by
impeding the flow of trade.
The effect on customs administration costs
back to top
Transaction valuation reform is among the
prominent measures that effectively facilitate commerce. Under the
auspices of the WTO, the reform is an important step on the road to
higher predictability and accountability of procedures world-wide for
determining the dutiable value. Because almost all trading countries of
the world implement the WTO customs valuation rules, importers and
exporters are in a better position to know in advance the amount in
duties payable, probably reducing the number of disputes and resulting
delays.
It was estimated that before the transaction
valuation reform and when the bureau required pre-shipment inspection
the total clearance time for imported cargoes ranged from 6.43 to 11.43
days. This period dropped to an average of 5.43 days when the customs
valuation reform was implemented, indicating a saving of from one to
five days.(14)
These improvements enabled the Bureau of Customs to save an average of
about 3.7 billion pesos a year, or US$67 per trade declaration. The
savings come mainly from terminating pre-shipment inspection: under this
reform the work can be done without paying for the valuation-related
services of a pre-shipment inspection firm.
V. Concluding
remarks: lessons learned back to top
The Philippines customs authorities and
private businessmen had serious concerns about this reform. The customs
agency feared that its revenue collection would be reduced, since it
expected the majority of importers to take advantage of its poor
capacity for enforcing compliance. Importers would undervalue their
merchandise and pay lower duties and taxes. If government officials were
worried that undervaluation would reduce collection, Filipino domestic
producers were concerned about the erosion of trade protection. Those in
the private sector who stood to benefit from the reform were in no
position as yet to fathom out the positive consequences. Thus the
prospects of poor collection and import competition dominated the policy
discussions at the time the government was adopting this reform.
Three and a half years later revenues have
gone up, but domestic producers are concerned. Officials tend to
underestimate the business response to price changes and accordingly
create implementation problems for themselves. There appears to be a
correlation rather than a trade-off between trade facilitation and
revenue collection. In pursuit of trade facilitation, customs
administration has become cost-effective.
Domestic producers are concerned, particularly
those facing potential adjustment costs because of increased imports.
However, there are those whose businesses are doing well because of
sensible adjustments made by their owners in the face of increased
imports due to the reform. Unfortunately, those producers with serious
asset specificity problems continue to hope that these reforms can be
undone and import competition reduced.
This case study gives the reader an insight
into the policy process. Economists tend to focus their analytical
energies on defining the equilibrium which promises to bring real income
improvements to an economy. It is, however, also important to understand
the process of how to get from where we are to the recommended improved
state of things. In the Philippines case, transaction valuation reform
was carried out twice, the second reform amending the first. It may be
useful to draw a few conclusions from this experience.
The policy process is a political transaction
involving two groups of stakeholders, each of which takes up and
advocates its position in a given spectrum of views about the reform.
Other stakeholders at the start of the process are uncommitted; each
group of advocates works to form a dominant coalition with the latter in
support of its position. At an appointed time, policy-makers and in this
case the Philippines Congress decide on a politically acceptable course
of action, that is, that which is supported by the dominant coalition.
The process itself involves the raising of
relevant issues by a group of advocates to which the other group would
have to respond well in order to win over the larger group of
uncommitted stakeholders. In the case of RA 8181, those who preferred
the status quo formed the dominant coalition. But, interestingly, they
did not get all they wanted, which was to block the reform itself and
continue with published home consumption values and pre-shipment
inspection. They had to compromise and accept some aspects of the law
that enabled transaction valuation. The reformers did not succeed
because they did not provide good answers in respect of the risk of
undervaluation. The resulting law enabled transaction valuation, so
decided because policy-makers reached a decision. The synthesis of the
policy process was RA 8181.
The exchange of the raising of issues and the
responses to them tended to improve the quality of the law. Ideas on how
to implement post-entry audits properly were the outcome of brokers and
importers asking for safeguards. The number of years during which an
importer was legally auditable was reduced from five to three. The law
required that the selection of importers to be audited ought to be
transparent and replicable and not arbitrary. How to organize the audit
group in a way in which discretion was reduced, transparency improved
and accountability defined — all these suggestions surfaced because of
the policy debates in Congress and clearly improved the initial ideas of
the customs authorities about post-entry audits.
The process is a continuous one, and every
policy reform has its proper time. The Philippines experience
demonstrates that RA 8181 was a poor political transaction measure and
as such becomes a stimulus to a continuation of the reform process. True
enough, the reformers came back in 1999, this time presenting post-entry
audit as a better substitute to published values. They succeeded and RA
9135 amended and improved the 1996 transaction valuation law.
Locking the reform in
back to top
The reform does not end with a piece of
legislation. There are its implementation and enforcement, which brings
this study to a parting remark. It is important for the present Customs
Commissioner George Jereos to ensure that there is an impartial
assessment of the implementation of customs audits and of the way in
which the young post-entry audit group (PEAG) at the Bureau of Customs
has dispensed its duty under RA 9135 and EO 160, which created it. The
risk to watch out for is that the audit group goes down the path of
arbitrary selection of those to be audited and in the search for
importers’ violations of the Tariff and Customs Code. The cost of
failure of post-entry audits is reduced collections, the lack of or
incomplete implementation of regulations, and corruption.
There are other improvements in implementation
that the Commissioner may want to consider. One is to improve its
product description convention so that it becomes more precise and the
list is regularly adjusted in line with the market. This reduces
unnecessary friction between customs authorities and importers regarding
the use of the value range information system. Finally, the super green
lane facility that started out as a means of appeasing anxious regular
and honest importers when pre-shipment inspection ended turns out to
have been a useful innovation in customs administration. The facility
has to be brought up to its full trade facilitation potential and
institutionalized, and the appropriate bureau resources appropriately
dedicated to the maintenance and upgrading of the facility.
NOTES:
1.- Cited in E. Medalla, Loreli C. de Dios and
Rafaelita M. Aldaba (1993), ‘An Evaluation of the Home Consumption
Value System’, Journal of Philippine Development, 20 (2), the
information was from a survey done in 1987 by the Société Générale
de Surveillance (SGS). back to text
2.- The ratification of the Uruguay Round Final
Act came first in late 1994. This was followed by legislation on the
agriculture tariffication in 1996, which rekindled the 1994 political
skirmishes on becoming a founding member of the WTO. When transaction
valuation was considered by Congress, the legislators were considering
at least four other such WTO laws, including subsidies and
countervailing measures, anti-dumping measures and safeguard measures. back to text
3.- As of Feb. 1999, the list of published
values reflected 1996 values according to customs officials. back to text
4.- The Bureau officials were not quite ready
to abandon pre-shipment inspection, and the week following the approval
of HB 8011 they met to adopt a contingency plan to reduce the risk of
undervaluation. Customs management planned to outsource the pre-shipment
inspection services for three years in order to calculate transaction
values to be used to check on the authenticity of the declared values.
The competitive bidding for this PSI would take place on 1 April 2000,
or after the end of SGS contract. The bidding, they conjectured, might
take half a year, during which the bureau would be without any
third-party pre-shipment inspection. If it could implement the
transaction valuation in that period, the officials would not go ahead
with a three-year PSI contract. back to text
5.- See Customs Administrative Order No.
2-96. back to text
6.- In 1998, the US Agency for International
Development in the Philippines provided the bureau technical assistance
to make them more familiar with the selection of importers to be
audited, operational aspects of post-entry audits and other
implementation issues related to transaction valuation. Experts on
post-entry audit trained customs officials on how to set up an audit
unit, on the selection of importers to be audited and the preparation of
the audit plan, the conduct of actual audits, and on the management of
the entire post-entry audit function. A few officials went on a study
tour sponsored by USAID/Philippines to the United States to see how the
US Customs Service conducts post-entry audits. back to text
7.- Based on author’s transcription of the
House of Representatives (HOR) Ways and Means Committee first public
hearing on HB 8011 on 29 Aug. 1999. back to text
8.- A resource person on one of the APEC-sponsored
training courses on transaction valuation agreement of the WTO brought
the idea to the Philippines. According to a provision in New Zealand’s
customs law which has never been used, compulsory acquisition gives a
legal right to a customs agency to purchase the merchandise. back to text
9.- Based on the author’s transcription of
the HOR Ways and Means Committee fourth public hearing on HB 8011 on 28
Sept. 1999. back to text
10.- Based on author’s transcription of
the HOR Ways and Means Committee third public hearing on House approved
HB 5623 amending RA 8181 on 15 Aug. 2000. back to text
11.- Based on author’s transcription of
the HOR Ways and Means Committee third public hearing on HB 8011 on 7
Sept. 1999. back to text
12.- See R. Clarete (2004), ‘Customs
Valuation Reform in the Philippines’, paper prepared for the World
Bank, mimeo, April. back to text
13.- Medalla, de Dios and Aldaba (1993). back to text
14.- The numbers reported here have been
obtained from UPECON Foundation (2003), ‘A Study on the Measurement of
the Time Required for the Release of Goods in the Republic of the
Philippines’, report submitted to the Bureau of Customs and Japan
International Co-operation Agency. back to text
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