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Political Significance of the Dispute

 

Proex

            The DSB Panel ruling on Proex as an illegal subsidy has disappointed many politicians and several Ministries in Brazil. Having designed the Proex I, and been the leading body responsible for maintaining the subsidy, the MDIC was most displeased with the ruling. Also disappointed was the Ministry of Foreign Relations who advocated the purpose of Proex throughout the duration of the dispute. Both these Ministries have already dedicated enormous efforts arguing to the DSB Panel that Proex does not confer a benefit to the buyer through the “financial contribution”, and thus is not an illegal subsidy.[1]

            Embraer uses around 80% of Proex’s budget for its exports, which is understandable considering that aircraft are extremely costly products and in turn the credits of its financing terms are also expensive. Proex is promoted by the BNDES bank because it enables small businesses to export their products. Indeed, small companies are the primary users of Proex, after Embraer , amounting to just under US$ 100 million annually.

        

Stakeholders

            The following are the main stakeholders who will be involved in Embraer ’s strategies to compensate for the restricted Proex, while endeavoring to put an end to the dispute with the Canadians:

The Ministry of Development, Industry and Commerce (MDIC)

The MDIC is responsible for several issues including: monitoring, orienting, protecting and regulating industrial development; tourism; industrial property rights and patent protection rules; and development of foreign trade. The Ministry was a strong supporter of Proex, playing a key role in its inception and design in 1991. Subsequently, it was responsible for redesigning Proex, as requested by the DSB Panel. It was this Ministry’s responsibility to formulate the conditions of Proex so that it would satisfy the requirements specified by the Panel in Report ‘WT/DS46/R’. The changes were made after receiving a resolution by the government’s Monetary Council on 6 December 2000. The Minister is Mr. Alcides Tápias, an active organizer of several of the current economic development programs in place.

            The MDIC’s responsibilities also involve participation in international trade negotiations, as well as the implementation of programs and activities related to foreign trade. Indeed, the Chamber of Foreign Trade (CAMEX) is part of the Ministry, setting the major policy decisions on foreign trade for Brazil. The executive of CAMEX, Roberto Giannetti da Fonseca participated in the design of PROEX, and has been a strong supporter of this measure, and other export support mechanisms over the past decade. Another department in this Ministry is the Secretariat for Foreign Trade (SECEX), responsible for the analytical work involved in preparing foreign trade policy decisions, including the formulation of Proex. The Secretariat of Industrial Technology, STI, is responsible for designing economic policies for the development of industrial technologies. Also, the National Bank of Economic and Social Development (BNDES) is located within this Ministry, designing policies to assist in the development of the economic sectors of Brazil.

 

Ministry of Science and Technology (MCT)

             The Ministry of Science and Technology is responsible for the formulation and implementation of national policies on science and technology. It aims for the improvement of scientific capabilities and knowledge, through training programs, and the development of technology to the benefit of the whole country.  Its goal is to create a climate conducive to research and development, and innovation. This may include developing R&D programs jointly run by private and public sector organizations, including universities.

             The Ministry of Science and Technology have several R&D policies aimed at developing public research institutions for use by the government bodies, private companies or universities. In cooperation with the MDIC, the Ministry helped prepare and pass the law the IT Law with administrative work, promotion and political influence.  MDIC designed and implemented the IT Law.

             The structure of MCT includes several agencies and technical commissions working on specific issues of technology, such as biosafety or nuclear energy. MCT also has an agency responsible for the development of scientific and technological development that manages major research programs and offers grants for scientific research programs around Brazil.

             The MCT guides the implementation of the IT Law (8.248/91) through the Secretariat of Information Policy (SEPIN). In the field of foreign trade, it has been involved with specific issues, such as e-commerce, lowering tariffs charged upon remittance of profits abroad from technology investments, and foreign technology transfer. The Minister is Mr. Ronaldo Sadenberg.

 

Ministry of Transportation

             The Ministry of Transportation is responsible for all policies related to transportation in Brazil. The Minister is Mr. Jose Henrique de Almeida Souza, who is a strong advocate of privatizing the transportation sectors of Brazil. He was involved in designing the program called “Develop Brazil”, a series of programs to upgrade the transportation infrastructure of Brazil, including international routes to the rest of South America.

 

Ministry of Foreign Relations (Itamaraty)

             This Ministry is highly engaged in international negotiations, including those relating to trade. They have, and will continue to play an important role in bringing about a solution to the dispute with the Canada. The Minister, Dr. Celso Lafer, has repeatedly stated the need to continue negotiations with Canada over the aircraft subsidies issue, and has also stood firm on maintaining Proex,.  He has also stressed the need to clarify to the WTO/DSB the role Proex plays for Brazilian exporters.

 

Canadian Department of Foreign Affairs and International Trade

            The Canadian trade representatives have challenged Proex and campaigned to in an effort to prove the legality of existing Canadian subsidies benefiting its aircraft industries.  Their tough stance on Proex reflects the pressure from Bombardier and other parts suppliers who fear the growing competition from the Brazilian rival. The Canadian trade representatives recently challenged the dispute Panel that specified the needed changes in order for Proex to become legally acceptable. Specifically, the Canadian delegation demanded that an additional ‘risk fee’ be charged on all financial transactions through Proex.  They claim such risk fees to be standard practice, and point out that such a fee is missing from Proex III.

 

Medium-to-Large Businesses

            It is mostly medium-to-large businesses that invest in research and development in Brazil. Only a minor portion of smaller enterprises in Brazil undertakes R&D due to the difficulties in undertaking R&D activities.  Among the difficulties that companies face are: the high levels of bureaucracy, a lack of financial support for investing in such activities, the lack of government programs facilitating the acquisition of technological equipment; as well as the relative deficit of highly-trained technological researchers.[2]  Indeed, these are the reasons for the lack of R&D expenditures by Brazilian businesses. However, there is an increasing trend among medium and larger companies to put more efforts into R&D as a way to differentiate themselves in their markets, leading to increased market share and competitive advantages.

 

Exporters Using Proex

            The businesses that presently benefit for Proex will oppose having stricter finance conditions as required by the WTO/DSB. Their main interest is to increase their exports abroad. They will need to be informed of any other alternative form of export credit programs that are developed in the future, as it is a relatively new field for most companies.  Most companies only discovered Proex in the late 90’s, even though it became available in 1991.

 

Federation of Industries

            The aim of the Federations of Industries in Brazil is to create better economic conditions for businesses and industries to operate. They act as a forum for discussion and debate on economic issues affecting their businesses, whether through conferences, meetings, or consultations with experts on the field of debate. The Federations are also engaged in attracting foreign investments, providing information on Government policies affecting businesses, and in developing specific sectors of the economy, such as biotechnology or IT. 

            Business associations have requested that tax incentives similar to those under the IT Law be given in the past few years to other sectors of the economy. The leading voice from this group is the Federation of Industries of the Brazilian states. The Federation in Sao Paulo (FIESP) has written several papers regarding this demand, and published Op-Ed articles in the country’s liberal newspapers. 

            The National Confederation of Industries (CNI) will be our strongest supporter in campaigning for this tax law, especially in administrative terms. The President of CNI, Mr. Carlos Moreira Ferreira, is also a Deputy of the state of São Paulo (PFL). He has been an active leader in legislative reforms that enhance Brazil’s business and economic environment. His most tenuous effort has been promoting a vast tax reform to eliminate the complexities inherent in the existing Brazilian system.

 

Labor Party and Unions 

            The Brazilian Labor Party (Partido do Trabalhador, PT) has historically challenged government policies aimed at enhancing production technologies with the argument that such policies result in unemployment for workers. PT has also been a strong advocate of reinforcing labor unions, and the labor unions who make their opposition legislative policies to known publicly through demonstrations, protests and advocacy. The leader of PT is Mr. Lula da Silva, who has run for President in the past three elections, only to be second in the running. Rumors have it the Lula may have a chance of winning the elections in 2002, though it is too early to make a good prediction. Even though they do not have a large presence in Congress, their partial coalitions with other parties enables the Labor Party to have an influence on policies being debated in Congress.

 

Ministry of Finance 

            The Ministry of Finance is responsible for formulating and executing economic policy. It is responsible for several matters including: fiscal policy implementation, and tax collection; currency, credit, and financial institutions; budgetary and financial administration; and, administration of public and domestic debt. When making policy decisions, the Ministry of Finance must consider Brazil’s heavy foreign debt.  The Minister, Pedro Sampaio Malan, has held this position for a long time (since January 1995), and has performed his duties very effectively, earning him the respect of other politicians. 

            The Ministry of Finance estimated that with the IT Law, it was foregoing between 610 million Reals (R$, Brazilian currency) and R$ 1.3 billion each year. Thus, the Ministry of Finance complained about the extension of the law, which resulted in the lowering the law’s of tax incentives. The Ministry has, however, recognized the increase in foreign investments attracted as a result of the law was, as well as the growing production from increased R&D expenditures in the IT industry.

 

Transportation Industry 

            The  purpose of my proposal is to benefit Embraer.  This necessitates preparing legislation that will affect the transportation industry and examining the Brazilian transportation industry. The current state of the Brazilian transportation infrastructure is relatively poor. There is much inefficiency including the extensive use of trucks to transport goods for long distances where rail transport would make more economic sense.  However, through a series of privatization moves during the 1990’s, more tracks are being transformed to offer efficient means of transportation, particularly in the southern region of Brazil. This industry will have to struggle to provide more transportation services over the already well-established trucking industry. Ports constitute further inefficient components of Brazil’s transportation infrastructure.   The current port systems are outdated and inefficient, and the cost of shipping products is extremely high by international standards. Businesses identified shipping costs as a main inhibitor to exporting goods. Indeed, the government has recognized this and written policies to renovate the ports. 

            The automobile and aircraft sectors enjoy better performance, though they still stand to benefit from government policies that encourage R&D because they invest the most in these activities.

 

Other Industries 

            Knowing that my proposal will affect other industries of Brazil, it is necessary to review the stakeholders from other industries who will also be impacted. Other than specific industries like pharmaceuticals, industries in Brazil tend to have relatively minor investments in R&D. Brazilian companies rate fairly low on the international scale of R&D activities.[3] However, the reason for this is not a lack of interest, but rather a matter of the problems explained above, coupled with the view that resources yield higher returns when invested in other areas of business.

 

State Governors 

            State governors are interested in having stronger manufacturing industries in their states. Considering that they are constantly looking for ways to attract foreign investment into their states, they would welcome a measure that would lower the operating costs of firms in their state. At the same time, they are concerned about state tax collection. Governors in Brazil have already demonstrated the significance of this matter in the passage of a bill that reduces the state-level circulation tax, called ICMS, in 1996 (Law No.8.820/96). Their political pressure to amend the law was a success, and half a year after its inception, the law was removed. 

Similarly, some governors have been arguing against the IT Law because they fear that their state’s loss of tax revenue has outweighed the economic benefits. In November of 2000, a group of governors campaigned against the extension of the IT law. However, their resistance was insufficient to stop Congress and the President from approving the extension. 

  


Analysis Section

 

Policy Analysis 

            The Ministry of Foreign Relations currently supports further  negotiations with the Canadian government over the aircraft subsidies dispute. In this case, the policy of diplomatic resolution of international contentions would be involved in any attempt to solve this trade dispute. My proposal would require the Brazilian diplomats to continue their diplomatic efforts with their Canadian counterparts; they would be encouraging them to restructure their subsidies to the aircraft industry. This effort will be key to meeting Embraer’s overall objectives  and Brazil’s foreign trade policy. 

             The MIDC will see the restriction on Proex as a reduction in the tools and programs created to reach its goal of developing the exporting activities of the nation’s businesses. The Ministry however, has designed other programs to promote exports, like the loans for exports administered through BNDES. There are loan programs designed for facilitating exporting by SME’s administered by BNDES, though they have low funds. 

             My proposal of a tax credit for R&D would allow Embraer’s export performance to continue at the present level in the short-term, and improve in the long-term, while allowing Itamaraty to continue its diplomacy efforts in pushing the dispute forward to a solution. While the proposal will not prevent the required changes set out by the DSB, which the Brazilian trade representatives have been fighting for over 5 years, it will create favorable conditions for companies to develop their technologies and comparative advantages, which in turn increases their chances of exporting their products.

 

How the Tax Credit Should Work 

Following the standard used by most of the G8 countries, the tax credit given to R&D investments is deducted from the company’s income tax owed to the government for the year. Any unused credits may be carried back 3 years or forward 10 years.[4] This is the case when the tax credit is higher than the income tax owed for that year. 

The R&D tax credit we propose will give a             preferential tax credit (50%) to the transportation industry, and a lower tax credit (20%) to the other industries. It should be noted that the following industries would be exempt from the R&D tax bill: 

o      IT sector (including the telecommunications sector): this sector already benefits from the IT Law. It would be unfair for it to receive two tax credits over one type of expenditure.

o      Petroleum industry: is still mostly government owned, and the government’s National Petroleum Agency (ANP), which is responsible for overseeing the liberalization of the industry, already has specific R&D programs for private companies purchasing into the industry. 

 

Brazil Cost 

            Over the past decade, the business community and economists have discovered setbacks caused to business’ international competitiveness as a result of Brazil’s financial and investment conditions. The term “Brazil Cost” was coined to refer to the existing conditions that hinder the efficient performance of a business domestically. Numerous studies have been conducted illustrating how specific factors of running a business in Brazil weigh on the production costs. The reasoning is that the factors of production in most foreign nations are not as high as in Brazil and so Brazilian companies are at a competitive disadvantage when competing internationally. Among the factors included in Brazil Cost are: 

  • Scarce availability of credit, i.e. high interest rates;
  • Poor infrastructure (transportation, telecommunications, energy);
  • Complex political system buried in bureaucracy;
  • Complex and burdensome taxation system; and,
  • Slow judicial system.

There are two goals in reducing the ‘Brazil Cost’: 1) to reduce the costs associated with running a business, leading to a more efficient business context and performance; and, 2) to lower the prices of Brazilian goods to make them more competitive internationally. 

            In the opening speech of a conference hosted by the Ministry of Science and Technology in March 2001, the President of the Institute of Industrial Development Studies (IEDI), Mr. Eugênio Staub, stated the problems that inhibit technological development and innovation in Brazil. According to Staub, these problems included “the small participation of the private sectors in national investments of R&D.” and “timid nature of concessions of fiscal incentives spread across the various sectors.”[5] Mr. Staub also blames the government for applying financial resources in the area of science and technology inconsistently, noting that less was invested in the field between 1998 and 2000 than between 1994 and 1997. It is therefore clear why the IEDI, the main industrial think-tank in Brazil sees  a tax incentive for R&D investments in all sectors of the economy as a valuable resource. 

Legislation for tax credits on R&D investments would be a tool to improve the Brazil’s business climate. Indeed the business environment in Brazil is not conducive to research and development. There is a lack of scientists and expert researchers because of the low-level of training available in the nation’s universities and research institutions, the result of which has been a low rate of return on R&D investments in companies, who then choose instead to invest in other activities. Secondly, there are few Government-led research programs available that relate specifically to industrial production or business methods. The burden is placed on businesses; however, the initiative to begin investing in R&D requires intensive capital and there are few available resources to support or expedite R&D. In the case of transportation, the recent push by the Government to privatize some areas of this industry, called ‘Sistema Nacional de Viação’ (Law 1.176/95), has meant that the private sector will have a large role to play in improving industry conditions and efficiency. This gives rise to a strong need for lowering the costs associated with developing new technologies in the Brazilian transportation industry. The sectors that would greatly benefit from tax incentives for R&D are the automotive, railway, aeronautics, and the shipping ports. The government estimates that it would take US$ 20 billion to restore the road and railway systems from their existing deteriorated conditions. Specifically for the ports, another US$ 20 billion was estimated in order to lower loading and freight costs through modernization of the current system. 

            In light of budgetary difficulties and the subsequent failure of the Ministry of Science and Technology to properly implement their programs, the tax credit would be an effective alternative to promote R&D investments. Although resources are allocated to the Ministry, allocations fall short upon implementation because project budget allotments do not account for additional administrative costs such as staff, social taxes, taxes and debt coverage costs. Halfway through 2001, the Ministry only managed to apply 3.3% of its budget for 2001, i.e. R$ 17.3 million out of R$519 million. The result is that several of their programs do not have the resources to be implemented, and those that do obtain resources receive only tiny amounts. This leads one to argue that there needs to be another way for the Ministry to implement its R&D facilitation and promotion policies. A tax credit for the private sector would achieve these policies without encountering the budgetary constraints of the Ministry.

 

Commercial Analysis 

Changing Proex 

            If the Brazilian government adapts Proex so as to abide by the DSB Panel’s requirements, the end price of each aircraft exported by Embraer will rise. Embraer needs to maintain the overall price as close to the current price as possible. It could theoretically achieve this by lowering the face value of its planes so that the end price, after taking into account interest payments from the loans, remains the same. However, the company’s current financial conditions impede this, as the net profit remains lower than the increase from the changes to Proex. Even though Embraer’s profits were over US$ 300 million, and knowing that the extra burden from the changes to Proex would be around US$ 300 million, the company already has plans for the profit, including building a new plant in São Paulo to keep up with demand.
  

Calculations of Impact From Using Proex III 

            As we saw before, the price of Embraer’s 50-seater (ERJ 145 ER) is US$ 18 million. And we also know that by using Proex III the end price to the customer rises by US$ 1million, thereby increasing to US$ 19 million per jet. The Price Elasticity of Demand (PED) is –0.7 for such aircrafts.

 

Exports:

Loss of Exports due to increase in Price from using Proex III:

P1= US$18 million

P2= US$19 million

PED[6]= - 0.7

 

Change in Demand of Embraer Aircrafts = -PED * ▲P

= -0.7 * (1 million/18 million) = -0.7 * 5.5%

= -0.039 = - 3.9%

 

Embraer’s expected sales volume for 2002 is around 220 aircrafts, therefore the change in demand is:

=220* -0.039

=- 9 aircrafts

 

Assuming that Embraer’s average sales volume for the next 5 years will be 200 aircrafts:

= 200 *-0.039

=- 8 aircrafts

For 5 years = 5 * -8

=- 40 aircrafts.

 

Therefore, the company can expect to sell 9 jets less in 2002, and 40 jets less in the next 5 years. In monetary figures we have:

 

The loss in export revenues in 2002 = 9 aircrafts * US$ 18million

= US$ 162 million

 

The loss in export revenue for the next 5 years = 40 aircrafts * US$18 million

= US$ 720 million

 

In terms of profit, we can expect the following:

 

The Net Profit Margin for Embraer for 2001 = 12%

So, the profit loss for 2002 = 0.12 * 162 million

= US$ 20 million

 

And the profit loss for the next 5 years = 0.12 * 720 billion

= US$ 86 million

 

To estimate the impact on the workforce we use the worker output rule. Knowing that the drop in sales is US$ 162 ml., we get:

 

= 162 ml./ 1,000 ml. * 6,000

= 972 employees

 

However, since plant is at full capacity it seems unlikely to result in actual layoffs.

 

Applying the R&D Tax Credit

            This section examines the commercial impact of implementing the R&D tax credit. To know the impact on Embraer, we need to know how much it spends on R&D:

Embraer spent US$ 180 million on R&D in 2000. The company is expected to invest US$ 900 million from 2001 to 2004 (approximately: US$ 200 for 2001).

Assuming a tax credit of 50% is applied, the credit will start counting for R&D expenditures for the year 2002 onwards. Embraer is expected to potentially save US$ 350 million from 2002 to 2004 (from US$ 700 million in R&D spending).

In 2002, Embraer plans to spend US$ 210 million in R&D, meaning that it will gain a tax credit of up to US$ 105 million.  Income before taxes is expected to be US$ 350 million. With an income tax rate of 35%, the company will owe the government:

Income Tax owed in 2002 = 0.35 * 350 million = US$ 122 million. 

The tax credit only applies to whatever income tax is owed by the company. In 2002, therefore, it can be expected that Embraer will only have to pay:
tax owed - tax credit = 122 million – 105 million = US$ 17 million
 

If all the money saved is used to lower the price of the jets through financing programs to the buyers, then:
Drop in Price = 105 million / 211 aircrafts = US$ 0.5 million per aircraft
= 0.5 / 19 million = 0.026 = 2.6 % drop in price
 

Using Price elasticity of demand:
Change in Demand for Embraer jets = -0.7 * -0.026
= + 1.6 %
= 211 * 0.016
= 3.4 aircrafts per year in the short-run
 

And in the long-run the PED raises because customers have adapted to the price changes and had time to switch aircraft manufacturers:
=PED * ▲Price
= -1.5[7] * -0.026
=+ 0.04 = 4 %
So, the actual increase in number of jets = 192 * 0.04
= 7.7 aircrafts per year in the long-run
 

In 5 years, Embraer will be able to recuperate around 31 jets in sales as a result of using the R&D tax credit. And since it will lose around 40 jets from the cut in Proex, the overall loss in sales of Embraer aircrafts will be around 9 jets in the next 5 years. This implies that the R&D tax bill will recover around 80% of the burden from using Proex III. 

            Therefore, the R&D tax credit would serve as a strong tool in permitting Embraer to maintain its end-price levels as close as possible to the Proex I level. Although a 50% tax credit would only recover a portion of the costs, the rest of the burden from adopting Proex III can be compensated by: profits, and the fact that tax credits should lead to additional R&D investments in the future, resulting in higher tax credit savings.  Most importantly, it will improve the growth prospects of Embraer  and enable Embraer to continue to compete with Bombardier, while ensuring greater innovation capacity through intensified R&D. 

            The savings from the R&D tax credit would also ensure that Embraer maintains the present level of jobs. Also, shareholders will benefit from the continued performance of the company [Note: Embraer sells shares at both the Sao Paulo Stock Exchange and NYSE]. Although the overall revenue level would remain slightly below the Proex I period, it can be expected that in the medium-to-long-term the increase in R&D activity should lead to improvements in aircraft design and specifications that increase performance and revenues. This comparative advantage may lead airlines to choose Embraer over Bombardier jets, ceteris parabus, assuming other things to be constant.



[1] SCM: Definition of a Subsidy, ASCM. WTO Website.

[2] World Bank report, 1997.

[3] World Bank, “Brazil –Science and Technology Reform Operation”, 1997.

[4] Lenjosek, ‘Why and How Governments Support R&D’.

[5] IEDI, Sep 2001.

[6] Estimate for short-run PED of aircrafts.

[7] Estimate for Long-run PED of aircrafts.

 

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