Stabilisation and Association Process Dialogue (SAPD) Trade, Industry, SMEs, Customs and Taxation. 11 May Conclusions

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Stabilisation and Association Process Dialogue (SAPD) Trade, Industry, SMEs, Customs and Taxation 11 May 2011 Conclusions INTRODUCTION The meeting of the Stabilization and Association Process Dialogue on Trade, Industry, SMEs, Customs and Taxation took place in Brussels on 11 May 2011. The meeting was opened by Lawrence Meredith, Head of Kosovo Issues Unit in DG Enlargement. It was co-chaired by Stefano Dotto, DG Enlargement, and Edon Cana, Secretary General of the Ministry of European Integration (MEI). The Kosovo * authorities were represented by Ministries and Agencies of the Government of Kosovo; The Commission was represented by the Directorates Generals for Enlargement, Enterprise, Taxation and Customs Union and Trade (please see attachment 1 for a detailed list of participants). TRADE KOSOVO TRADE WITH EU - EXCHANGE OF STATISTICAL TRADE DATA The Kosovan authorities presented the trade flows for 2010. During 2010, the Kosovo trade exchange reached an amount of approximately 2.5 billion (15.8% more than the previous year). Kosovo s imported goods totalled 2,139 million, with annual growth around 10.5%. Kosovo s exports recorded a value of 294 million, or 77.8% increase compared to 2009. 38% of exports are on regular basis, 51.7% are considered re-export, 97.2% regular imports, and 2.3% re-imports. Kosovo exports during 2010 were oriented towards the EU countries, reaching over 131 million or 44.7% of total exports. Imports from EU countries are over 821 million or 38.4% of total imports. In the trade exchange with EU countries, major trading partners include Germany, Italy, Greece, etc. Trade turnover for 2010, with regional countries (CEFTA members), reached over 86 million. Import s value is 799 million, or 37.3% of total imports. Exports with destination toward CEFTA member states are over 70 million, or 24.1% of total exports. * Under UNSCR 1244/1999.

Kosovo exports unprocessed metals (or scrap metals) and mineral products worth over 223 million, or 76% of total exports. Exports of this category have increased over 96 million (or over 100% growth compared to last year), and this has greatly influenced the growth of total Kosovo exports. The structure of imports remains similar to the previous year. Imports are dominated by mineral products, machinery and equipment category amounting to a value of 32.8% of total imports. Comparing with the previous year, imports in this category have increased from 331 million to over 413 million. Other imported categories such as transportation means have decreased 12% compared to the same period last year. Data for exports by product show that nickel covers 47.6% of total exports, an increase of 115% compared to 2009; ores and lead concentrates cover 5.4% of total exports (an increase of 93% compared to 2009). Other most exported products are copper, steel, zinc and aluminium. Kosovo s major imported products are: petroleum oil making up 9.3% of total imports, iron (or steel bars and rods) 2.7%, light oil and preparations 2.2%, energy 2% and tobacco with 1.9% of total imports. Challenges: Facilitating businesses to increase their trade exchange in general, exports in particular. EC comments: In recent years, the trend shows that Kosovo exports to EU on average are increasing quicker than imports from EU which is a positive sign concerning development. A composition of exports with higher value added commodities would be more beneficiary for Kosovo. Follow up actions: Drafting the Law on Foreign Trade to replace the Law on External Trade Activities No. 2002/6 (Q2 2011) EXPERIENCE AND PERSPECTIVE OF CEFTA CHAIRMANSHIP Achievements: Kosovo actively participated in all meetings. Kosovo participated in the second Strategic Meeting held on 23 September 2010 in Belgrade. From 10 to 12 November 2010 Kosovo participated in the CEFTA week held in Belgrade. During the CEFTA Week Kosovo attended the second meeting of the Trade and Services Working Group. Kosovo participated in the Experts meeting on 11 November 2011.

On 12 November 2010 Kosovo participated in the Joint Committee Meeting at the ministerial level. During September-October 2010, a Working Programme of Kosovo with regards to chairing CEFTA was prepared. The Working Programme of Subcommittee on Agriculture and Sanitary and Phyto-sanitary Measures for 2011 was prepared and distributed during December-January. During 2011 this subcommittee will be chaired by Kosovo represented by the Ministry of Agriculture and Rural Development. From 1 January 2011, Kosovo for the first time chaired an international mechanism. On 11 March 2011, Kosovo chaired the third meeting of the CEFTA Steering Committee held in Brussels. On 19 April 2011 Kosovo participated in the Working Group Meeting on Technical Trade Barriers (TTB) in Belgrade. Challenges: Recognition of Kosovo Customs stamps. Removal of barriers for free movement of goods, even in transit (barriers from CEFTA members Serbia and Bosnia and Herzegovina), which are in contradiction with the CEFTA Agreement and international principles for an open and free market economy. Future plans: Chairing the Subcommittee for Agriculture and Sanitary and Phyto-sanitary Measures. Chairing the Working Group for Trade in services. Chairing the meeting of the Deputy Ministers (expected to take place by the end of June in Pristina) and experts meeting Chairing and organizing the traditional CEFTA week. Chairing and organizing the Joint Committee Meeting at the ministerial level (November 2011) EC comments: The Commission follows closely the implementation of CEFTA by all eight Parties. The Commission shares the expectations for recognition of customs stamps, but encouraged Kosovo to use the CEFTA Dispute Settlement Mechanism. As chair, Kosovo has the obligation to ensure the good functioning of CEFTA. Hence, Kosovo should use the institutional mechanisms within CEFTA to solve the disputes. Any retaliation would be a breach of the agreement. The Commission is providing technical assistance for chairing CEFTA, but the assistance should not prevent members from developing ownership of the process. The Commission requested the Kosovan authorities to confirm that the Joint Committee meeting will take place on 23 November in Paris back to back with CEFTA week. Confirmation was given.

The Commission agrees that Foreign Direct Investment is the way for enhancing economic performance. Stability and improved economic governance are two fundamental conditions for attracting foreign investment. Without those two conditions foreign investors will not come to Kosovo. Concerning ATMs, the reason for not extending them is mostly linked to the new Treaty entering into force. Once the regulation is in force the ATM s will be retroactive. The Commission requested that the Kosovan authorities provide a detailed impact assessment of damages related to the delay in renewing the ATMs. Follow up actions: Kosovo is to provide the Commission with a detailed impact assessment of the consequences for Kosovo exports due to the lack of ATMs (Q3 2011). CUSTOMS AND TAXATION CUSTOMS Achievements: All secondary legislation for Customs Laws in place by March 2011. Customs organigramme 2011 has been approved. From January to date, 22% of the annual projected revenue has been collected, an increase of 30.9 million or 21% compared with the same period of 2010. The Unit against organized crime is in place and working. The Office for Coordination with the Prosecutor is established. Concerning the fight against smuggling and organized crime, a total of 600 operations has been carried out, of which 455 cases were in the North (TASK Force Customs & Police). 627 Customs offences 757.757. Customs offences in first quarter 2010 137 cases. Customs offences in first quarter 2011 353 cases. Regarding the fight against corruption, the Customs Action Plan 2011 has been revised; field inspections are being carried out; Customs is part of the implementation of the National Strategy against Corruption (3 cases under suspicion for abuse of official position, involving 8 customs officers). The Unit for Intellectual Property Rights (IPR) upgraded to a sector. Intelligence officers covering IPR issues are now located at major border crossings. 8 trademarks registered (9 to be registered). 15 confirmed cases for violation of intellectual property rights. 161,621 units of counterfeit products worth 600,000 seized. Regarding Integrated Border Management (IBM), starting in January 2011 Examination/ Mobile Units have been put in place all around the border. This has resulted in a better use

of personnel; increased number of customs offences detected, and increased revenue collection. Standard Operating Procedures of law enforcement sectors have been approved. Further improvement of inter-agency cooperation achieved including exchange of intelligence and access to Personal Identification Secure Comparison and Evaluation System (PISCES). A government decision has been taken to create a body called International Law Enforcement Cooperation Unit (ILECU) which includes customs. Systematic Electronic Exchange of Data (SEED) agreement on exchange of information signed with the former Yugoslav Republic of Macedonia (1 October 2010) and Albania (11 January 2011). Bilateral agreement signed with the Customs service of the former Yugoslav Republic of Macedonia (11 February 2011). Engagement on regional activities (Venice Declaration). Customs still receives technical assistance from the EU-CTA project covering IT, IPR and IBM. Assistance received since 9 July 2009 is set to end by 23 September 2011. Due to this technical assistance, the IT strategy has been adopted, the IPR Action Plan and SOP are to be approved soon and a few IBM study visits and seminars were conducted. Challenges: Achievement of revenue collection projected (the government plans to collect 19% more revenue than in 2010 or nominally 131 million more). Addressing the Blueprint gaps (final report to be delivered to beneficiaries in mid 2011). Further engagement on fighting corruption, organized crime and smuggling. ASYCUDA and its implementation (already approved by Parliament). IT tools in enforcement are to be upgraded to allow integration of more databases (such as IPR). Future Plans: The continuation of full deployment of the ASYCUDA IT system in the future. EC Comments: Concerning the Venice Initiative, THE COMMISSION supports any cooperation of Member States and Western Balkans. However, the Venice Initiative is not a Commission Initiative; hence it will not appear in the Progress Report. Customs encouraged to reflect next year on using risk analysis tools available in ASYCUDA, and to try incorporate as much as possible results from the exchange of information that will become available now under the systematic Exchange of Data (SEED) project to target accurately the physical and documentary controls. The Commission encourages the Western Balkans to sign MoUs with other neighbouring countries that are part of the SEED (such as the one between Kosovo and the former Yugoslav Republic of Macedonia).

To focus in the near future on reducing the overall number of random physical controls in order to conduct more targeted physical checks. This will also facilitate trade. Full documentary checks for every declaration is a burden for trade. Next year begin to move to more targeted risk analysis once the customs has the IT tools, which will result in more targeted controls and a better facilitation of trade. The Commission was informed by the Kosovo Chamber of Commerce that customs clearing procedures are long and tedious and that sanitary and phyto-sanitary inspections could not take place during weekends. The Commission asked about the status on the draft law on excise of tobacco products which was supposed to be approved by the government by 31 March 2011 according to the Legislative Strategy 2011. Follow up actions: IPR Action Plan and SOP to be approved (Q2 2011). Draft of new Customs and Excise Code to be approved and start its implementation (Q1 2012). Mutual Technical Agreements to be signed with Italy and Slovenia (Q4 2011). More trademarks to be registered within Kosovo Customs/Intellectual Property Office (Q4 2011). Beside the examination mobile teams which started in January 2011, there are also administration/acceptance teams in the concept of the mobility scheme of the IBM by the end of the year (Q4 2011). Full deployment of the ASYCUDA IT system (Q3 2011). TAXATION Achievements: New Law on Tax Administration and Procedures passed. Administrative Instructions drafted. Draft amendments to the VAT Law to clarify some issues related to international transactions and exemptions, also reduction in VAT threshold to 30,000. Approved Strategic Plan for the period 2010 2015. All audit inspectors (approximately 260) trained in the new VAT Law and Administrative Instructions to improve the administration of VAT in Kosovo. Taxpayer Advocate appointed and actively involved in resolving taxpayer issues. The Risk Management Unit has been established. Fully staffed and trained Tax Investigation Unit established. Key Performance Indicators established and monitored. Annual reporting requirement for businesses making purchases of 500 implemented.

Updated Albanian version of the TAK website; English and Serbian versions still in process. Revised MIS reports available on internal website to improve their utility to management. Established training commission to oversee development of training materials and increase effectiveness of TAK training. Updating of Audit and Collection Handbooks is finished. Upgrade of core IT system (SIGTAS) completed. All forms now on TAK website for downloading with bar-coded and pre-printed information the only source of forms for taxpayers. Payments made at commercial banks are now processed directly into the taxpayer s account. Program for receiving data from fiscal cash registers has been implemented. Program for implementing electronic filing has been completed. Digital archiving of declarations has been implemented. Total tax revenue for 2010 was 221.6 million, a 7% increase compared to 2009 and a 14.9 million increase over the 2010 goal. 94.6 million pension contributions collected. Revenue target for 2011 is 261 million, an increase of approximately 20% over the 2010 revenue. As of 18 April, 65,619 fiscal numbers have been issued. 12,950 fiscal cash registers have been installed in 9,730 businesses. 1,835 audits concluded in 2010 proposing an 54.6 million in additional tax; 5.7 million VAT credits reduced through audit. 85,737 compliance visits made at businesses. 43.8 million collected through enforced collection measures. 20.4 million in VAT refunds issued. Database clean-up With the upgrade of SIGTAS and issuance of fiscal numbers, TAK is concentrating on establishing a reliable database in order to improve management of nonfilers, tax debtors, and regular taxpayers. New Law on Tax Administration and Procedures clarified, Authority of Office of Professional Standards (OPS) to include: a) Authority to do background checks on prospective or new employees. b) Authority to review financial statement information of TAK managers and employees. c) Clarified that OPS has authority to conduct investigations of potential corruption of TAK officials under the guidance of a prosecutor.

14 cases of improper behaviour and corruption investigated (for the period September 2010 to April 2011). Disciplinary action taken against 5 officials. Challenges: Backlog of cases at the Independent Review Board. The 2011 budget for the Tax Authority is very limited and provides limited funding to resolve space issues, vehicle issues, etc. Beginning to operate in North Mitrovica. Implementation of a new performance management process. Revenue target for 2011 is 261.2 million, a 20% increase compared to 2010. Future Plans: Further implementation of fiscal cash registers. Development of training course materials for audit, collection and taxpayer education staff and delivery of associated training. Development and implementation of TAK call centre. TAK receives assistance from: EU through EUCTA project, USAID through ESTAK project, and IMF through technical assistance. EC comments: Current number of registered taxpayers is low 1. The Commission encourages TAK to focus on combating unregistered economy in order to extend the taxpayer base and avoid an overly formalistic approach on reliable registered taxpayers. The Commission encourages TAK to make progress regarding the backlog of cases at the Independent Review Board. The Commission outlined that the lowering of VAT threshold is very good progress. The Commission noted that according to the Chamber of Commerce fiscal cashiers are being installed and not used either on purpose or due to lack of instructions particularly by some SMEs. The Commission wondered whether the reporting on transactions over 500 is overloading the capacity of TAK to process the data and causing a detriment of the more fundamental tasks of the Tax Administration. Follow up Actions: Address the backlog of cases at the Independent Review Board (Q3 2011). Establish an operational office in North Mitrovica (personnel have already been recruited: 8 inspectors; Q3 2011). 1 Tax Administration clarified that after the issuance of fiscal numbers, all taxpayers are registered

INDUSTRY AND SME POLICY INDUSTRIAL STRATEGY Achievements: In September 2010 the Industrial Strategy was to be presented to the government for approval but this did not happen due to government changes. The statistical data about industry of Kosovo was updated and submitted to Kosovo Statistics Agency. Preparation of a sectorial analysis for Kosovo industry. Identification of the legal needs in order to facilitate procedures. Challenges: Factors inhibiting industrial development: Primary infrastructure (electricity, water, etc.) Fiscal policy and still high custom taxes for the import of raw materials. The risk of price increase for raw materials. Competition of the informal sector. Political issues regarding the use of natural resources (Trepca, unresolved political status of northern part of Mitrovica municipality, where the mining processing facilities remained in the northern part devised from the mining extracting part). Products manufactured with old technology, etc. Future plans: To strengthen the cooperation with local government and the SME Agency in order to achieve a better coordination of activities. To improve conditions for the development of industrial SMEs, by facilitating access to business locations, advancing public services and public infrastructure and urbanization. Intensification of sustainable social and environmental development, energy efficiency, clean technologies and recycling industry. Support for the development and intensification of marketing activities and research development. Designing training programs for employees, which would improve the growth of labour productivity. EC Comments: The Commission suggested synergy of strategy implementation in order to improve effectiveness and in the same time to avoid overlapping initiatives.

The European Commission has adopted a Communication on industry policy, the so called Integrated Industrial Policy for the Globalization Era. This communication is a flagship initiative of the Europe 2020 Strategy, and the Commission encourages the Industrial Directorate to consider it. Follow up actions: Industrial Strategy to be approved by the government of Kosovo (Q4 2011). Development of the plan for implementation of obligations arising from the strategy document (Q1 2012). SME POLICY Achievements: Continual coordination of the implementation of the EU Small Business Act (SBA) with stakeholders (government institutions, non-institutions, social partners, chambers of commerce and unions) in Kosovo, which are obliged to report for the 119 indexes of SME policies based in EU SBA. The ISCED-2, 5 and 6, following the TNA (Training Need Analysis), which comes out from the South Eastern European Entrepreneurial Learning in Zagreb (SEECEL), has been implemented. Substantial work in establishing a SME Western Balkans Association (currently in its preliminary phase). The Voucher Scheme offered 2,657 days of training and consultation for start-up businesses. During the reporting period, 78 new business advisers have been introduced (accredited) bringing the total number of advisors up to 300. This year, five business plans were approved in the competition Business Plans Competition and the winners have already opened active businesses. In the project Business Internship Program 230 students have been awarded with one month internships within Kosovo SMEs. The Competence Catalogue has been launched, aiming to ensure cooperation between Kosovo SMEs and institutions that are offering expertise and consultancy in different fields (March 2011). Drafting of the SME Development Strategy 2012-2016, with vision 2020 has been completed. There were 25 working group meetings organized; about 50 meetings with other relevant stakeholders were conducted; 5 workshops (2 central and 3 regional workshops organized); and 1 National Conference held. Initiatives for the establishment of new Economic Zones - application of 15 new municipalities. Business Park in Drenas: 37 Businesses, 1,050 employed and investments of over 31 million.

Task Force within the Prime Minister Office for improving Kosovo rating on WB Doing Business Report has been established (aim position 40 by 2014). Challenges: Business incubators do not have sufficient resources for more effective functioning. Future plans: To become part of European net of incubators. Substantial informal sector which inhibits formal sector. Existing non-loyal and anti-competitive behaviour in the Kosovo market (market surveillance instrument not fully functional). Low level of vertical and horizontal relations between enterprises. Reform of judicial system to give more effective support to economical rights. Reducing unforeseen judicial risks the effectiveness of contract enforcement. Increasing competition by applying more in depth legal reform for better classification in the WB Doing Business Report. Insufficient access to finance for SMEs. To strengthen the cooperation between local authorities, different ministries and the SME Agency in order to achieve better coordination of activities. Strengthening the Legislative and Regulatory SME Framework. Improving SME access to finances. Promoting and developing an entrepreneurial culture. Strengthening the domestic and international competitiveness of SMEs. Improving the dialogue between private and public sectors. Strengthening SME support institutions. Development of technical, innovative, and managing skills of SMEs. Incorporation of international standards and quality managing system to the SMEs. Development and Establishment of Business Zones and Innovation. Facilitation and access of SME s in Regional and International Markets. Awareness building of role of SMEs in economical development. Improvement and strengthening of the capacities for business organizations and for other subjects that covers economic sector. Capacities strengthening and effectiveness of the SME Agency on the coordination of SME strategy implementation. Cooperation with agencies for regional development for the implementation of the SME Strategy. Capacity development of municipal business centres.

Improvement of qualifications of individual business consultants and business service providers. EC Comments: The Late Payment Directive has been adopted (January 2011); the SBA (Single Business Act) has been reviewed (February 2011) due to the post -crisis situation. Adoption and effective implementation of the strategy on SMEs is required. The SBA process for Turkey and Western Balkans is ready to be launched. Follow up actions: Approval of the SME Strategy (Q2 2011). Drafting of the Plan for Implementation of the Strategy (Q3 2011). Regarding the improvement of the business environment in Kosovo 12 laws will be adopted 2 (Q3 2011). Support of municipalities with feasibility study in regard of establishing their own business parks (Q4 2011). INVESTMENT PROMOTION AND CLIMATE Achievements: Investment Promotion Strategy completed, awaiting approval by Minister of Trade and Industry (focus on demand-side dynamics of the investment promotion business). New focus: targeting country, sector, company (pro-active promotion, direct contact, visit to companies and presentation of concrete projects). CRM and database location near completion (client relationship system and database of investment location sites and local projects). Business Process Outsourcing (BPO) (identify potential foreign investors, search the market to identify local companies that are interested in joint ventures, target, visit and attract). 2 1. Draft law on Amending Custom Code and Excise in Kosovo No. 03/L-109 MF 2. Draft law on amending of the law No.02/L-41 on Fire Protection MI 3. Draft law on Construction MESP 4. Draft law on amending the law No.02/L-123 Trade Associations MTI 5. Draft law on amendig the law No. 2004/18 on Internal Trade MTI 6. Draft law on amending the law No.03/L-10 on Notary MJ 7. Draft law on amending the law No.2003/25 on Cadastre MESP 8. Draft law on Accounting, Financial Report and Auditing MF 9. Draft law on amending the law No. 2002/6 on External Trade Activities MTI 10. Draft law on amending the law No. 03/L-065 on Integrated Border Menagment MPB 11. Draft law on amending the law No. 03/L-008 on execution procedures MD 12. Draft law on amending the law No. 2002/5 on establishment of the register of real estate MESP

Export Promotion Strategy near completion. Ten Business to Business (B2B) meetings in USA, Austria, Switzerland, Greece, Netherlands, Turkey, Slovenia and Albania. Around 200 Kosovo companies participated. Seven trade fairs in UK, Croatia, Albania and Montenegro. 20,000 visitors. 200 companies participated from Kosovo. Total sales 2 million. IPAK has improved its services for foreign investors by offering an effective and efficient one stop shop (increasing staff members, technical assistance from EU SME Project and Italian Trade Commission, Database Location and CRM, new building and IT equipment). Marketing activities (publication of Investors Guide, Top 10 reasons to invest in Kosovo, Fact Sheet, CDs, pocket pamphlet). Publication of e-newsletters distributed to 4,500 potential investors. Marketing in international magazines (the European Times, Kosova Haber). New brochures (Business Process Outsourcing, Legal Guide to Kosovo). Continuous cooperation with donor programs (ECLO, KPEP/USAID, DAI/USAID, BEEP/USAID, DFID, ADA, UNDP, TIKA, TAM/BAS, Swiss Cooperation Office, JICA/JETRO). Inter-ministerial working group for reform of the business environment (No. 16/146, date 29.09.2010). Technical Group of legal officers established (No. 14/2011, date 01.02.2011) World Bank Doing Business document prepared for improvement in 5 indicators. Publication of Findings and Recommendations licenses and permits at central and local level. Bilateral agreements on investment protection and promotion, technical drafts negotiated with Albania, Macedonia, Turkey, Slovenia, Germany and Switzerland. Challenges: Lack of resources budget and human resources. Future Plans: To continue identification of obstacles in the process of obtaining licenses and permits whether at central or local level. EC Comments: Commission welcomed the upgrading initiative on licensing and permits at central and municipal level. Follow up actions: Complete drafting of the Export Promotion Strategy (Q3 2011). Establishment of Foreign Investment Council (Q4 2011).

List of participants for the SAPD on Trade, Industry, Customs and Taxation No Institution Names Position e-mails 1 MEI Edon Cana General Secretary of MEI Edon.cana@ks-gov.net 2 MTI Florent Bakija Advisor to Minister of MTI 3 MEI Rajmonda Kukalaj Director of the Department for Economy and Trade 4 KC Naim Huruglica General Director, Kosovo Customs 5 TAK Behxhet Haliti General Director, Kosovo Tax Administration 6 TAK Nahit Sharku Modernization Director, Kosovo Tax Administration 7 KC Zana Batusha Head of International Department, Kosovo Customs 8 MTI Shaban Halimi a.d Director of Industry Department 9 MTI Naser Grajçevci Chief-executive of Agency for SMEs 10 MTI Mustafë Hasani Chief-executive of Agency for Investment Promotion 11 MTI Igballe Rexha- Jashari Head of Division for Trade Policies florent.bakija@ks-gov.net rajmonda.kukalaj@ks-gov.net Naim.hururglica@dogana-ks.org Behxhet.haliti@atk-ks.org Nahit.sharku@atk-ks.org Zana.batusha@dogana-ks.org Shaban.halimi@ks-gov.net Naser.grajcevci@ks-gov.net Mustafe.hasani@ks-gov.net Igballe.rexha@ks-gov.net 12 MTI Flamur Keqa Director of Trade Flamur.keqa@ks-gov.net Department 13 MF Rexhep Vasolli Head of European rvasolli@mfe-ks.org Integration Office 14 MEI Jeton Karaqica Senior Officer for Jeton.karaqica@ks-gov.net Economic Development and SMEs 15 EC Lawrence Meredith DG Enlargement Lawrence.Meredith@ec.europe.eu 16 EC Stefano Dotto DG Enlargement Stefano.Dotto@ec.europe.eu 17 EC Philippe Cuisson DG Enlargement Cuisson.Philippe@ec.europe.eu 18 EC Mihaela Ciudin DG TRADE Elena-Mihaela.CIUDIN@ec.europe.eu 19 EC Juan José Garcia Sanchez DG Taxation and Customs Union Juan.GARCIA- SANCHEZ@ec.europe.eu