9002lirpA IN PRACTICE investment climate BUSINESS OPERATIONS AND TAXATION 5.on 48316 Local Taxes, Regulations, and the Business Environment Finding the right balance Regional and municipal governments play a key role in establishing a Laurent Corthay local business environment that is attractive to foreign and domestic investors. However, in many countries, entrepreneurs face a complex Laurent Corthay (lcorthay@ worldbank.org) is a Private Sector web of local taxes, regulatory fees, and other charges. This situation Development Specialist in the increases the costs and risks of doing business, thus limiting the World Bank Group's Investment Climate Department (CIC). He potential for business growth, investment, and job creation. This advises governments on reform- note explores the roots of this problem and introduces options for ing business regulations and tax administration in order to reduce addressing it. barriers to compliance, invest- ment, and growth in developing countries. He is currently support- ing the design and implementa- Local governments and the revenues2 (tax and non-tax), intergovernmental tion of reforms in Burkina Faso, business environment transfers, debt, and profits from public the Kyrgyz Republic, Madagascar, undertakings or shares in companies. The Sierra Leone, Vietnam, and the The local business environment1 is determined financing mix varies widely depending on the by government policies and regulations that degree of decentralization, and the level (regional Republic of Yemen. affect enterprises. Subnational governments' vs. municipal), type (urban vs. rural), legal status decisions directly impact the way businesses (degree of autonomy), and welfare (rich vs. This note and others in the operate through local taxes and user charges; poor) of the local government3 (see Box 1). series of IN PRACTICE notes on businesslicensesandpermits;land,environment, business taxation reform were de- health, and safety regulations; and enforcement For businesses, the combination of local taxes veloped as part of a joint program mechanisms and procedures. Moreover, to the and fees may represent a heavy burden in terms extent that they provide access to infrastructure, of financial and administrative costs. This is between DFID (the United King- utilities, and other benefits, local governments particularly the case when local governments use dom's Department for Interna- are essential in creating and maintaining payments related to licensing and other tional Development) and CIC. The environments that attract foreign and domestic regulatory instruments to generate revenue. program focuses on operational investors. issues in tax reform, particularly As many countries become more decentralized,4 those related to micro-enterprises Even in relatively centralized countries, local subnational governments face increasing governments have the responsibility, and often pressure to find sustainable sources of revenue. and small businesses. Within CIC, legal obligation, to deliver services to citizens Intergovernmental transfers are not always the business operations and busi- and businesses. To finance this mandate, they sufficient or forthcoming, revenue bases from ness taxation product lines jointly typically rely on a combination of "own-source" standard taxes are limited, and local governments developed this note. in poor regions may not be able to borrow money. significant are the heavy compliance costs driven Moreover, local governments often have limited by numerous instruments and requirements and authority to impose taxes, but are often granted the overall complexity of the administrative discretionary power to establish or enforce aspects system. The package of taxes and fees may also of business regulation. All of these factors provide amount to high financial costs.6 When local incentives for local governments to find new administrations have the ability to introduce new revenue sources, which can lead to the burgeoning fees at their discretion, arbitrary and unpredictable of local fees.5 conduct on the part of administrators may result. The system's opacity leads firms to consider all payments as "taxes" in a confusing scenario How does the proliferation featuring visits from multiple "tax" collectors. The of fees affect businesses? potential for corrupt practices increases, through inspections and more interaction between The proliferation of local taxes and fees creates a businesses and local authorities. complex web of procedures and payments that can impose a significant burden on businesses. Most Ultimately, nuisance factors and heavy compliance costs weaken business productivity and may act as barriers to entry, thus limiting economic growth.7 Surveys of informal businesses indicate that this sort of environment encourages firms to operate Box 1: The Multiplicity of Local Taxes and with some degree of informality, which can limit Fees in the Republic of Yemen the government's revenue base and companies' growth potential.8 In the Republic of Yemen, 55 types of fees are used to finance local Local governments also bear costs.9 Administering authorities. Some, such as the annual district (municipal) operating regulation is expensive and not the most efficient fee, are subdivided into more than 500 categories of business size and way to raise revenue. It absorbs scarce qualified activities. According to the law, a similar charge--the professional human resources that could be put to more permit fee--must also be paid at the governorate (provincial) level and productive use. The complex architecture also is subdivided into 68 different categories. Companies are also required decreases transparency and accountability because to pay an annual registration fee to the Ministry of Trade and Industry, collecting, allocating, earmarking, and using locally generated revenue is not straightforward. a membership fee to the Chamber of Commerce, various monthly local council support fees (surcharges on utility bills), city improvement fees Regulatory decision-making may also be distorted. (surcharges on specific common transactions), and a range of sector- Forinstance,decisionsmaybebasedonmaximizing specific regulatory fees. Companies are also subject to the zakat, originally revenues rather than on protecting the public a religious tax (2.5 percent on capital) that is used as a business operation interest or addressing market failures. Excessive levy assigned to local authorities. and unnecessary regulation may be introduced; for example, each of multiple agencies may require a firm to hold a separate license to operate in its All of these payments are in addition to the standard taxes (corporate jurisdiction. income tax, goods and services tax, property and property transfer taxes, fuel tax, and a tax on insurance contracts), as well as earmarked contributions to social, transport, and development funds. In sum, a What is a local "tax"? medium-sized fishing company registered in Aden, for instance, would Defining what constitutes a local "tax" depends on typically have to pay up to 15 fees plus standard taxes. The same is true for point of view. Businesses generally consider any a hotel or construction company located in the capital city of Sana'a. payment made to a public agency as a tax, regardless of the jurisdiction. Politicians may play Source: FIAS (unpublished 2009 desk review of Yemeni legislation). with definitions to serve their objectives (see Box 2). IN PRACTICE BusINEss OPERATIONs ANd TAxATION 2 For the purpose of analysis, local "own-source" revenues are classified into four categories: Box 2: Is It a Tax or a Fee? Standard taxes are compulsory payments that feed into public finances and are not tied to specific goods or services government delivers for the "The Democrats have devised a plan to get around [California's budget taxpayer's direct benefit. Standard taxes impacting crisis], albeit a desperate and legally questionable one. They want to businesses include those on land and property, relabel taxes as "fees" and increase them. Although it takes two-thirds income, sales, and excise taxes on products such as of legislators to pass a tax increase, fees could be increased by a simple alcoholic beverages, cigarettes, and automobiles. majority vote. Republicans, who have more than a third but less than The assignment of taxes at the local level varies by half of the seats in both chambers of the legislature, would be overridden country, depending on how fiscal decentralization is structured. [...]". User charges are payments that are directly tied to Source: Economist (2009). the purchase of goods and services delivered by the public sector. User charges, like prices in a market, usually vary with consumption. They typically include payments linked to garbage collection, water or electricity (when provided by the public sector). To be viable, user charges should be set at full cost recovery plus return on investment. Table 1: Typology of Local Own-Source Revenue Instruments Regulatory fees are payments linked to a wide variety of instruments such as licenses, permits, Instrument Revenue Source Examples and certifications. In principle, these fees are meant to cover (all or part of) the cost of administering Standard taxes Compulsory payment; base (a) Profit or corporate income tax varies by instrument the regulation. (b) Property (land and building) taxes Other non-tax payments from businesses to local User charges Revenue from sales of goods (a) Utility fees (water, gas, electricity) governments, in the form of interests, royalties, and services provided directly and rents (mainly on natural resources and by the government (b) Garbage collection fees government properties) as well as fines and Regulatory fees Revenue from licenses and (a) General business/trade license fees penalties, constitute another important set of permits for regulated activities, revenue sources. (Table 1 provides a summary of and delivery of administrative local revenue instruments.) services (b) Construction permits (c) Examination and inspection fees How are regulatory fees used? - Interests Revenue from public assets, (a) Admission fees (national parks, Licensing is a common type of regulation that - Royalties and property resources under historical sites) concession fees government custody, and affects specified businesses and occupations by - Rents and fees for natural resources to which (b) Road and bridge tolls regulating entry into markets and conduct within usage rights property rights are not assigned markets. Licensing typically imposes a range of (c) Public works (rents on buildings, hire obligations and rights on firms. Breach of licensing charges) conditions often results in sanction by the relevant regulatory authority, such as a fine or revoked Fines and penalties Punishment for non- (a) Traffic/parking fines permission to perform an industrial activity. compliance with the law or regulation (b) Penalty for late payment/notification Licensing and other business regulations may Source: Adapted from Das-Gupta (2004). involve agencies charging a fee to deliver the license or administer the regulation. From the firms' IN PRACTICE BusINEss OPERATIONs ANd TAxATION 3 perspective, fees are payments to the government generating and regulatory instruments. like taxes. Distinctions between the types of Inefficiencies and excessive burden arise when payments become blurred when fees have no clear governments use regulatory instruments to raise link to the government performing its regulatory revenue, which is accomplished more efficiently function. The key distinction is between revenue- through taxation. Three forms of misuses with regulatory fees and other such payments are among the most common. First, the introduction of regulatory instruments Box 3: Principles for Imposing (such as licenses, permits, and other forms of Licensing Fees authorizations) may occur without a justified regulatory rationale; the purpose is purely revenue While this note emphasizes the costly consequences of regulatory fee collection. Second, the fee collected is greater than the cost of administering the regulation. Finally, misuse, imposing such fees need not be negative. Government agencies when licensing generates significant social gains to can appropriately impose regulatory fees in a transparent manner: the community, excessive fees can act as a tax on these public benefits (see Box 3). On a cost-recovery basis, when licensing generates direct benefits for the firm receiving the license;a An integrated approach to When the business generates negative effects on the broader local business environment community, such as pollution. reforms10 However, when licenses generate broader benefits for the community (such Local business environments can be improved by as enhanced health, safety, or security outcomes) than for the business, rationalizing the use of regulatory fees. This has then imposing licensing fees may be inappropriate and inflict undue costs not been dealt with very effectively in developing on the community. In such cases, license fees essentially impose a "tax" countries, in part because practitioners have failed to integrate regulatory and fiscal aspects of the on services provided by business that benefit the broader community. problem. Because the rationalization of regulatory In this situation, the taxation system should ideally be strengthened so instruments typically affects local public finances, that inefficient and costly fees can be reduced over time and eventually efficient and effective tax options need to be offered replaced by more efficient revenue mechanisms (including strengthened to compensate for lost revenues and deliver intergovernmental transfers or an appropriate local business tax). sustainable local reforms. There are four key steps to integrating reforms of Such measures are sustainable only when a functioning, broadly based the local business environment (see Figure 1): taxation system is in place. When this is not the case, establishing such a 1. Start with a comprehensive inventory of all system should become a long-term objective. In the short-run, however, instruments involving a payment made by when regulations protect broader policy objectives (such as health, safety businesses to local authorities. and the environment), then license fees may be applied if two conditions 2. Check the legality of the instrument. If the are met: legal basis is not robust, then the instrument Revenue collected provides tangible benefits for the community that should either be eliminated or legalized (if it clearly exceed the direct and indirect costs on the business and the serves a legitimate purpose). community of collecting license fees; and, 3. Categorize inventoried instruments based Licensing revenues are collected more effectively and at lower cost on the standard definitions discussed in this than broader taxation measures. note. 4. Single out regulatory fees, and assess the purpose of the instrument: a. For a detailed report on cost recovery, refer to Productivity Commission (2001). When it serves a legitimate regulatory Source: FIAS (2009). purpose, the instrument may be kept and the process streamlined, where possible. Fees IN PRACTICE BusINEss OPERATIONs ANd TAxATION 4 should generally be set on a cost-recovery Options for reforming local basis. taxes and regulations11 When the purpose is primarily to generate revenue, when no regulatory function is Reformers must closely monitor the revenue performed, or when revenue collected is impact of proposed changes to regulatory fees, greater than the cost of regulating, the because eliminating or rationalizing them will likely weaken the revenue base of the concerned instrument may be considered a disguised government agencies. To compensate, local tax. In this case, three options should be governments may need to rely more heavily on considered: to eliminate such quasi-taxes; intergovernmental transfers, but that is not always to collapse them, where applicable, into possible. Other options include merging multiple a local business levy; or to rely on other fees into one local business levy and strengthening fiscal instruments, including transfers, to own-source revenue instruments such as taxes and user charges. compensate for the revenue loss. Merging fees into one business levy. When the authority introduces "regulatory" fees to raise revenue but does not perform a regulatory function, such fees are de facto taxes that are Figure 1: A Four-Step Reform Process Elimination / Legalization 1 2 Comprehensive Legal? Inventory User fees and charges Maximize use, and set fee as cost-recovery plus return on investment 3 Nature of Standard taxes instrument? Apply principles of revenue productivity, accountability, equity, simplicity, and non-distortion Regulatory fees and charges Licensing and permit fees Interest, royalties, and rents Business patents and other charges Fines and penalties 4 Purpose of Instrument? Legitimate regulatory purpose Revenue-generating purpose: quasi-tax Set fees on cost-recovery basis Merge fees into one local business levy Streamline procedures to limit compliance Eliminate and address revenue through and administrative costs tax policy and/or intergovernmental transfers Source: Author. IN PRACTICE BusINEss OPERATIONs ANd TAxATION 5 inefficient and distortionary. However, while their levy that merges several instruments into one. This introduction may represent abuse by the local practice allows for a revenue-neutral simplification government, it may also be the administration's of the system, which still benefits businesses (by only alternative in the absence of a broad-based tax reducing administrative costs to comply and system and reliable transfers. In such a context, improving transparency) and government (by multiple fees may be replaced by a single business simplifying the system and reducing costs to administer it). Two commonly cited examples include the single business permit in Kenya12 and a low-rate gross receipts levy in Tunisia.13 Although this approach seems appealing, it is not particularly Box 4: The Challenge of Consolidating easy to execute (see Box 4). Multiple Fees in Kenya User charges. Governments should charge for the The local licensing and revenue collection practices in Kenya are goods and services they deliver whenever possible--except for licenses and other services characterized by a high level of informal economic activity, insufficient that generate broader benefits to the community, budgets and poor regulatory governance, which has led to a proliferation as highlighted above. When local governments rely of licenses, fees, and burdens on both formal and informal businesses. on user charges, they are seen to deliver services for a price within a market context. User charges also Prior efforts to ease the burden of the local government licensing system provide information about demand to public on businesses have yielded the opposite result, although local revenue has suppliers, because consumers will only pay for services they want. This dynamic should enhance increased. When local governments introduced a single business permit economic efficiency and fairness. Although it can (SBP) between 1999 and 2000, the SBP became the third most important be difficult to design and implement good-practice source of revenue after the Local Authority Transfer Fund (from the user charges, they should be considered whenever national government) and property-based collections. According to a feasible; in most cases, they are one of the most 2006 study, the SBP represented nearly 16 percent of all locally generated desirable ways for local governments to generate revenues, while pre-SBP revenue from licenses amounted to 7 percent. revenue. Local business tax. In many countries, local But with the introduction of the SBP, the burden on formal businesses business taxes include corporate income tax, increased because local officials arbitrarily applied the purportedly capital taxes, non-residential property taxes, and progressive bands of the SBP. The SBP is now cited by businesses as one various forms of commercial levies. Business taxes of the main deterrents to business activity at the local level. tend to be popular with politicians as well as citizens; they often produce substantial revenues and voters generally prefer to shift taxes from Businesses that are formal (to a greater or lesser extent) still face higher themselves to firms. The economic case for a local administrative and financial costs under the SBP, and they are subject to business tax is that it sometimes can be considered other charges and fees that should have been consolidated into the SBP. a benefit tax. Business taxes have been faulted, Local authorities in Kenya also rely on production, transport, and market however, for their distortionary impact on cesses as output taxes collected at the time of sale or transit. These cesses companies' location decisions. When poorly affect informal businesses as well. Businesses also complain about coercive designed, they may also constrain business with heavy financial and compliance burdens. enforcement and rent-seeking by local officials, which foster taxpayer resistance and encourage evasion. Several proposals have advocated for a "business value tax"14 that would differ from a conventional Recent reforms to streamline the SBP are expected to significantly reduce value-added tax (VAT): it would be levied on the administrative and direct financial costs on businesses across the business income, taxing production (not country by an estimated $11 million annually. consumption), and assessed on the basis of annual accounts (not transactions). To limit the risks of harmful tax competition between jurisdictions, a Sources: Kenya, Ministry of Local Government (2006) and FIAS research. floor (and possibly a ceiling) could be put in place. Although this tax is not an ideal instrument, it has IN PRACTICE BusINEss OPERATIONs ANd TAxATION 6 been conceived as a less harmful alternative than business. Local governments are able to operate IN PRACTICE other business levies when local revenues need to more efficiently and fulfill their core functions, be strengthened. It is not designed for small which are important to the private sector. enterprises that do not keep formal accounts, Integrated reforms help create attractive The IN PRACTICE note series which limits its potential base. However, where the environments for a range of investors from small is published by the Investment context allows, this practical measure could help start-ups to multinationals. Climate Department (CIC) of the compensate for the elimination of more World Bank Group. It discusses distortionary instruments such as excessive fees. Over the long term, sustaining local business practical considerations and environment reforms may require that higher levels approaches for implementing Property taxes. Property taxes have long been of government allocate more revenue-raising hailed as the only appropriate general tax source for autonomy to local authorities and hold them to reforms that aim to improve local governments because they target immobile hard budget constraints. Until this happens, local the business environment. The factors (buildings or land), thus avoiding distortion politicians will likely continue to rely on whatever findings, interpretations, and and harmful tax competition across jurisdictions. revenue-raising instruments are available to them, conclusions included in this note These bases are visible and not easily hidden, so even when fees are excessive or distortionary. The are those of the author and do not property taxes are less subject to evasion by alternatives highlighted in this note offer reformers necessarily reflect the views of the taxpayers (although this is less true when building a head start in the right direction. censuses are infrequent, particularly in fast-growing Executive Directors of the World areas). A low-rate uniform tax on property or rental While integrated business environment reforms are Bank or the governments they value can be an important tool for local no silver bullet, they have the potential to sustain represent. governments to secure revenues. However, it long-term local development. Investing in a low- should not be overplayed. In fact, property taxes compliance cost tax regime helps build a future in have proven difficult and costly to administer, which businesses can operate more efficiently, the About the Investment particularly due to discretionary aspects in assessing tax base widens, and the tax burden is more broadly Climate Department the value of real estate. distributed. The high visibility of property taxes has both CIC assists the governments positive and negative effects. It may enhance Endnotes of developing countries and government accountability and responsibility, but transition economies in reforming also makes taxpayers highly sensitive to property 1 This includes both national and local policies and their business environments, tax increases. With property taxes, taxpayers make regulations, which exacerbates the complexity of the with emphasis on regulatory regular, large lump-sum payments directly to environment in which businesses operate. This note simplification and investment governments, whereas other taxes are more invisible focuses on the local level exclusively, which encompasses the regional and municipal levels. because they are directly collected when taxpayers generation. CIC relies on close 2 Own-source revenues are taxes and other levies assigned earn (payroll deductions) or spend (sales and excise to local governments, which collect them and have some collaboration with its donors and taxes). As a result, it is always challenging to degree of control over rates. World Bank Group partners-- 3 increase revenue from this source through higher A wide body of research on subnational finance and International Finance Corporation rates. It is also difficult and costly to maintain the fiscal decentralization deals with these issues. This note focuses on local taxes and fees exclusively. (IFC), the Multilateral Investment property tax base by keeping up-to-date building 4 See Shah (2004), for instance. Guarantee Agency (MIGA), and censuses. 5 See Taliercio (2005) for examples of proliferation of local taxes and fees in East Asian countries. FIAS research the World Bank--to leverage documents similar cases in other regions. value and deliver tangible results Conclusion 6 This may affect small firms more heavily as fees are often fixed amounts. It is also likely to divert more of for client governments. CIC is managers' time.in small businesses who may not have the operational center for IFC's Local governments are particularly prone to the dedicated staff to deal with it. Business Enabling Environment misuse of regulatory instruments as revenue 7 See Iarossi, Saliola, and Tanzillo (2006) and Dollar, Advisory Services and FIAS, the mechanisms. By reforming regulatory and revenue Hallward-Driemeier, and Mengistae (2003) for systems jointly, local governments can eliminate an studies of the impact of administrative burden on firm multi-donor investment climate productivity; see Djankov, McLiesh, and Ramalho array of distortionary levies and secure more (2006) for a study of the impact of regulatory costs on advisory service of the World efficient revenue streams. Streamlined, more growth. Bank Group. transparent revenue structures and business 8 For example, see USAID (2008). 9 regulations reduce the financial and compliance See Lewis (2006) for a study of the administrative cost costs imposed on firms and the risks of doing inefficiency of local taxation in Indonesia. 10 See Rozner and Gallagher (2008) for a detailed guide IN PRACTICE BusINEss OPERATIONs ANd TAxATION 7 following a similar approach to reforming taxes and the International Development. Washington, D.C. business enabling environment. http://www.fiscalreform.net/index.php?option=com_content& 11 This section does not cover the full range of tax task=view&id=775&Itemid=52 instruments occasionally used at the local level. Refer to Bird (2006a) for an in-depth and more comprehensive Iarossi, Giuseppe, Federica Saliola, and Giovanni Tanzillo. coverage. 2006. "Business Climate, Productivity, and Competitiveness 12 See Kelly and Devas (2001) for an analysis of Kenya in Armenia: 2002­2005." 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