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THE COOEPRATION COUNCIL FOR THE ARAB STATES OF THE GULF

SECRETARIAT GENERAL

TECHNICAL SECRETARIAT FOR ANTI-INJURIOUS PRACTICES IN INTERNATIONAL TRADE

ANTIDUMPING QUESTIONNAIRE

Intended for Foreign Producers/Exporters

PLEASE NOTE THAT THIS QUESTIONNAIRE HAS TO BE COMPLETED AND PROVIDED IN FOUR COPIES:

TWO AS CONFIDENTIAL VERSION

AND TWO AS PUBLIC VERSION

1

INDEX

INTRODUCTION.......................................................................................................................... 3

GENERAL INSTRUCTIONS........................................................................................................ 4

1.GENERAL DATA....................................................................................................................... 7

1.IDENTITY OF THE COMPANY:..........................................................................................................72.LEGAL REPRESENTATIVE:..............................................................................................................73.LEGAL ENTITY:...............................................................................................................................74.ACTIVITIES:.....................................................................................................................................8

2. THE PRODUCT UNDER INVESTIGATION...........................................................................9

.3 FINANCIAL STATEMENT AND ACCOUNTING SYSTEM.................................................12

4. SALES...................................................................................................................................... 14

TURNOVER.......................................................................................................................................14EXPORT SALES OF THE PRODUCT UNDER INVESTIGATION TO THE GCC STATES...........................14DOMESTIC SALES OF THE LIKE PRODUCT IN THE COUNTRIES...................................................17EXPORT SALES OF THE LIKE PRODUCT TO THIRD COUNTRIES.......................................................19

5. PURCHASES AND STOCKS..................................................................................................20

PURCHASES.......................................................................................................................................20STOCKS.............................................................................................................................................21

6. PRODUCTION AND COST OF PRODUCTION....................................................................22

6-1 PRODUCTION..............................................................................................................................226-2 COST OF PRODUCTION...............................................................................................................22

7. ATTACHMENTS..................................................................................................................... 24

8. ANNEXS.................................................................................................................................. 46

ANNEX 1: CERTIFICATE....................................................................................................................46ANNEX 2: GLOSSARY........................................................................................................................47ANNEX 3: GUIDE FOR ADJUSTMENTS..............................................................................................50ANNEX 4: GUIDELINES FOR COMPLETING THE NON-LIMITED DATA..............................................56

2

INTRODUCTION

With reference to the GCC Common Law on Antidumping, Countervailing and

Safeguard Measures and its Rules of Implementation, this questionnaire aims to

obtain the necessary information to carry out the antidumping investigation of the

Public Notice issued in Volume (17) of the Official Gazette for the GCC-Bureau of

the Technical Secretariat of Anti-Injurious Practices in International Trade (GCC-

TSAIP) due to the complaint lodged by the GCC domestic Industry against the

imports of Ceramic flags and paving, hearth, floor, or wall tiles; whether or not on a

backing; finishing ceramics, which are imported under the GCC-Unified Tariff Code

from item 6907 other than those of subheading 69073000 originated in China, India,

and Spain, (hereinafter referred to as the “product under investigation"). It is in your

own interest to reply to this questionnaire as accurately and completely as possible

and to attach all supporting documents.

It is imperative for the continuation of the proceeding to reply to all questions in

the formats requested and within the time limits specified by the GCC-TSAIP as

indicated in the general notes therein. All documents attached to this questionnaire

should be signed and stamped by or on behalf of your company.

If you have any problems completing the questionnaire, please contact the GCC-

TSAIP officials in charge of the proceedings who will provide you with any

explanation on any question contained in this questionnaire.

3

GENERAL INSTRUCTIONS

1. Before completing the questionnaire you are requested to read

and review carefully all instructions therein and the glossary of

dumping terminology attached as Annex2.

2. This questionnaire is intended for the foreign exporting

producers exporting the product under investigation originating

in China, India, and Spain.

3. The purpose of this questionnaire is to permit the GCC-TSAIP to

obtain the necessary information to carry out the investigation

and on the basis of which preliminary and final determinations

will be made with reference to the GCC common Law and its

Rules of Implementation.

4. The response to this questionnaire must be completed in English

on the official paper of your company.

5. Please put your answers in the order presented in this

questionnaire. In order to do this, rewrite the question to which

you are responding in your narrative submission and put your

answer directly below it. If for any reason because of the nature

of the response required, it is impractical to be able to do this,

please attach more attachments for more details indicating

clearly to which question they relate and indicate the extent of

confidentiality whenever it is required.

6. Any methodology used in allocation of costs and revenue to

different types of the product under investigation, should be

clearly explained.

7. The responses to the questionnaire must be based on sufficient

evidence supporting the data contained therein, which requires

identifying sources of data submitted.

8. Please respect the deadline specified for replying this

questionnaire. Any interested party may request, upon proper

4

justification, an extension of the deadline before the ending of

the initial deadline.

9. All cost and pricing information should be provided for the

period of investigation for dumping ( POI) from 1st July 2017 to 30th

June 2018. If your company’s financial year differs from the POI,

please give a detailed explanation of how the information was

compiled for the POI.

10. The GCC-TSAIP may carry out on-spot visits to examine

the records of your company and to verify the information

provided in this questionnaire. For this reason, all worksheets,

documents and records used in answering this questionnaire must

be retained.

11. The confidentiali ty will be fully respected in the

proceeding. Therefore, where appropriate, certain information

and supporting evidence may be given on a confidential basis.

Any information or document provided as confidential must be

labelled as ‘’confidential’’. These confidential data will not be

made available to any other interested party.

12. Moreover, any party providing such ‘’ confidential’’

information is required to provide a non-confidential summary

thereof which is open for inspection and examination by

interested parties. Such summaries shall be in sufficient detail to

permit a reasonable understanding of the data submitted as

‘’confidential’’.

13. The questionnaire with its tables and attachments should be

submitted (confidential and non-confidential copies) in hard copy

and soft copy (using WORD or PDF for text and EXCEL for

data).

14. Identify clearly all units of measurement and currencies used in

all submitted data.

5

15. All documents submitted in reply to this questionnaire must be

accompanied by an English or Arabic translation.

16. All correspondence must be sent by mail service or presented

personally to the following address:

Bureau of Technical Secretariat For

Anti-Injurious Practices in International Trade

Riyadh – The Kingdom of Saudi Arabia

P.O Box: 7153

Code: 11462

Tel: 00966112551388

Tel: 00966112551341

Fax : 00966112810093

Email: [email protected]

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1. GENERAL DATA

1. Identity of the company:

Legal entityName

Place of Export/ProductionDate of establishment

CapitalDate of beginning of export/production

WebsiteAddress

Tel/Fax

2. Legal representative:

If you have appointed a legal representative to represent you, please provide the original power of attorney in Attachment (1-1) with the following details:

Name of legal representative:

Nature of the legal representative work:

Address: ………………………… Fax: ………………………………

Tel: ………………………………... Website: ………………………….

Email: …………………………….

Official in charge: ……………………….

(Name and responsibility)…………. Tel: ……………………………….

Email: …………………………… Fax: ………………………………

3. Legal entity:

State the legal form of your company:

Individual/private company□Limited company□

Limited partnership by shares□Limited partnership□

Other (specify) ……………□Partnership□

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Corporation□

Provide copies of the following documents (in original language and in

English):

Articles of Association and all related documents to be attached in

Attachment (1-2). Provide details regarding changes in these Articles of

Association since the original establishment.

Business License in Attachment (1-3)

4. Activities:

Please indicate the activities of your company:

Producer□Retailer □

Exporter□Wholesaler□

Distributor□Other (if any)□

5. Indicate the date of establishment of your company. Please attach any catalogues

or brochures issued by your company in Attachment (1-4).

6. Supply a diagram outlining the overall organizational structure of your company

in Attachment (1-5). Show all units involved in any way with the product under

investigation.

7. Identify your parent company/ies if applicable. Provide the names & addresses

and detail the extent of its ownership in your company.

8. Provide a list of all affiliated companies and their addresses. Describe the

relationship between your company and its affiliated companies and provide

details of the percentage of ownership held by your company and its affiliates.

9. Complete the Attachment (1-6) concerning the affiliated companies of your

company which are involved in any way with the product under investigation

and/or the like product.

10. Complete the Attachment (1-7) concerning the details of the shareholders of

your company who own individually more than 5% of the shares in the capital

and provide details regarding any changes in these shares during the period of

investigation. 8

2. THE PRODUCT UNDER INVESTIGATION

The product under investigation is the imported product to the GCC from …..

11. Provide in Attachment (2-1) all documents related to the product under

investigation of your company such as catalogues and brochures.

12. Clarify a detailed description of the product under investigation produced and

sold by your company and/or its related companies in terms of:

Technical characteristics of the product

End-uses

HS Code when exporting

Attach a complete flowchart of the production cycle and give a

description summary of the main stages of the production process and

the raw materials used in production.

Distribution channels (Retailer, Wholesaler, Distributor, OEM …etc.)

Periods in which the production and sales of the product under

investigation are increased.

Other (specify)

13. If your company uses coding system for its production and sales of the product

under investigation, please describe in details your company’s product coding

system for each Type/Model of the product under investigation including the full

range of prefixes, suffixes and other notations that identify and specify the

different types/models of the product in Attachment (2-2).

14. In case your company does not use the same product codes in the production, and

sales, or does not use the same code depending on the sales market, provide

cross-references in Attachment (2-2) linking the codes used in the production

department with those used in the sales department.

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15. For the purpose of the fair comparison between the export sales and domestic

sales in addition to matching the sales data to the relevant cost of production, it is

important that your company and its related companies use throughout the

response to this questionnaire a consistent coding system when referring to the

different types/models of the product under investigation. This code is known as

“Product Control Number - PCN”. It is especially important that the PCN be

used consistently in all electronic files, even if the company’s code(s) used for

sales or production are different from the PCN. The PCN has to be created for

each type/model of the product under investigation produced and sold by your

company and its related companies according to the following characteristics:

PCN Field description

Symbol format Explanation of Symbol

Type/Model category

CW/ CF/ PW/ PF/…..etc.

CW: Ceramic Wall TileCF: Ceramic Floor TilePW: Porcelain Wall TilePF: Porcelain Floor TileEW: Extruded Wall TileEF: Extruded Floor Tile

Water Absorption

W0/ W1/ W2 W0 : <=0.5%W1 : >0.5% <= 10%W2 : >10%

Finishing Z0/ Z1/ R0/ R1/ P0/ P1

Z0: Unglazed Z1: GlazedR0: Unrectified R1: RectifiedP0: UnpolishedP1: Polished

Sizes Provide classifications for “Tile Piece Area” G1/ G2/ G3/ G4/ G5/………..etc.

G1: 0-100cm (i.e. 5x5, 5x10, 10x10…etc.)G2: >100-400cm (i.e. 11x11, 10x20, 20x20….etc.)G3: >400-900cm (i.e. 21x21 29.5x29.5, 30x30….etc.)G4: >900-1600cm (i.e. 25.5x45, 40x40 ….etc.)G5: >1600-2500cm (i.e. 50x50, 20x120….etc.)G6: >2500-3600cm (i.e. 40x80, 60x60….etc.)G7: >3600-4900cm (i.e. 70x70, 60x80….etc.)G8: >4900-6400cm (i.e. 75x75, 80x80….etc.)G9: >6400-8100cm (i.e. 90x90, 60x120….etc.)G10: >8100-10000cm (i.e. 81.5x100, 100x100….etc.)G11: >10000cm other different sizes could be added whenever needed.

Please do not use any separator or spaces within the PCN code in all Excel sheets.

Example:

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Porcelain floor tile with water absorption 0.5%, glazed, rectified and polished

with size 60x60cm: (PFW0Z1R1P1G6).

If you have any suggestions as to how the specifications of the product types

produced and sold by your company could be more appropriately reflected,

please don’t hesitate to contact the GCC-TSAIP.

16. Correlate your company’s product coding (i.e. production codes and sales codes)

provided in Attachment (2-2) with the created product control numbers (PCN) in

the same attachment and explains in detail how the created PCNs are linked with

your company’s production and sales codes.

17. Complete the Attachment (2-3) relating to the differences, if applicable, among

the exported product to the GCC (product under investigation), the like product

you sell in your domestic market (domestic like product), and the like product

you export to a third country (exported like product).

18. Regarding the units to be used in your reply to this questionnaire, you should

normally apply the same measurement consistently throughout your questionnaire

response. Unless otherwise specified, where we request “volume” you should

report in (square meters). Furthermore, all sales prices and values should be

expressed in the currency in which your accounts are kept.

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3. FINANCIAL STATEMENT AND ACCOUNTING SYSTEM

19. Identify your company’s financial year. If any changes have occurred regarding

this accounting year during the period of investigation, please explain these

changes.

20. State whether your accounting practices comply with the generally accepted

accounting principles (GAAP) in your country. If the principles employed by

your company vary from the GAAP, explain the nature of the difference, and the

reason a different principle was adopted.

21. Provide your company’s method for treatment of fixed assets and the related

depreciation expense. Describe whether these assets are revalued periodically. If

your company does revalue assets, provide a description of the process, including

the accounting entries that are recorded and the frequency of the adjustments.

Identify the indices used for revaluation adjustments and provide index tables

covering the past three years including the POI.

22. Describe your financial accounting system in details indicating the accounting

methods used in preparing your financial statements, and all principles which

have a significant impact on the cost of production, including the explanations of

the following:

- Inventory evaluation (FIFO,LIFO,AVERAGE.) for each of (RM, WIP,

Finished Goods);

- Average useful life for each class of production equipment and

depreciation method and rate used for each including any accelerated

methods;

- Whether standard or actual costing methods are used.

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23. In the event that any of the accounting methods used by your company changed

over the last three financial years, provide a detailed explanation of the changes,

the date of change and the reasons for it.

24. Attach copies (with English translation) of the audited financial statements

including all auditors’ reports, notes and opinion in Attachment (3-1) for the last

three financial years including the POI for your company as well as for related

companies that are involved in production, marketing and sales of the product

under investigation.

25. If you keep separate books for each department/division in the company please

provide balance sheets and income statements for each of them before

consolidation for the last three fiscal years including the POI.

26. Provide full details on your company’s Auditors (i.e. name, address, telephone,

fax, email, and website).

27. Provide a copy of your company’s chart of accounts including the numbers and

names of the accounts used in Attachment (3-2).

28. If your company uses an accounting software, provide the following:

- Name of the accounting software

- The beginning date of use.

- Is the company still using the manual accounting system beside the

software?

29. Provide a list of exchange rates for your domestic currency against the U.S. dollar

(or any other currency of exportation to the GCC) in Attachment (3-3) for the

period of investigation (POI) and identify the source of the information.

14

4. SALES

TURNOVER

30. Complete the table in Attachment (4-1) for the period of Investigation

concerning the following:

a. Total Company’ sales of all products.

b. Sales of the product under investigation to Unrelated Customers.

c. Sales of the product under investigation to Related Customers.

31. Provide any studies about the product under investigation or the like product in

Attachment (4-2).

EXPORT SALES OF THE PRODUCT UNDER INVESTIGATION TO THE GCC STATES

32. Explain how the selling prices are set (pricing methods) of the product under

investigation by providing all the information relating to the terms and conditions

of sale of the product under investigation in terms of:

Delivery Terms: FOB, CIF,C&F ..... etc.

Payment: In advance, upon delivery, Credit (specify no. of days).

Policy of granting discounts and rebates: quantity discount, value/cash

discount, .....

After-sales: Warranty, Maintenance contract, ...etc.

Other (if any)

33. Describe how your prices to each customer are determined. If sales are in

accordance with price lists, supply copies of all lists that applied during the

period of investigation in Attachment (4-3).

34. Complete the table in Attachment (4-4) for all sales of the product under

investigation to the GCC Countries during the period of investigation (POI).

Provide (PDF-format and hard) copies for all export invoices of each export

shipments to the GCC Countries of the product under investigation. Furthermore,

15

attach (PDF-format and hard) copies of the export sales related documents for 5

export shipments of the product under investigation.

35. Complete the table in Attachment (4-4) relating to the breakdown of all the

charges incurred after the ex-factory price on export sales to the GCC of the

product under investigation during the POI (prices’ adjustments). Provide

evidence and working papers to explain each adjustment for 5 invoices.

36. Explain your company’s channels of distribution to the GCC member states for

the product under investigation starting from the factory gate up to the first resale

to independent customer. Describe the sales process for each method or channel

of distribution described and provide a detailed flow chart indicating all details

(i.e. terms of sale, pricing, customers) in Attachment (4-5).

The description you provide on your distribution and sales processes is

intended to provide the GCC-TSAIP with the information necessary to make

appropriate comparisons of sales at the same level of trade.

37. Explain the relationship between your company and your customers

(exporter/importers) mentioned in your reply to Attachment (4-4) and provide

enough details for that in Attachment (4-6) including list of customers’

categories (i.e. OEMs, Distributors, Retailers, End-users), selling activities

performed in details.

Refer to definition of "affiliated person" in Annex 2.

38. Explain the sales negotiation process of the product under investigation starting

from contacting with the customer (purchase order) up to the delivery of the

product under investigation to this customer. Provide flow chart indicating all

details in Attachment (4-7).

39. Clarify whether a change occurred in the distribution channels or in the sales

negotiation process described above during the period of investigation and the

reasons for that.

40. Please provide copies of contracts (with English translation) between your

company and your customers for export sales to GCC (either long-term or short- 16

term), describe in detail the process by which the contracts, the prices, expenses,

and quantities therein, are agreed to. Describe each type of contracts applicable

to the product under investigation, including the terms, the requirements for a

price change or re-negotiation by either side, etc.

41. Were the prices of the product under investigation that were exported to the GCC

member states during the POI:

i) Subject to any direct or indirect reimbursement to your customers (e.g.,

sales promotion, advertising, warranty, etc)? Or,

ii) Influenced by a commercial agreement or relationship including

mutual corporate affiliations and / or common shareholders.

iii) Inclusive of any consideration other than price.

Refer to definition of “Arms-length transactions” in Annex 2).

17

DOMESTIC SALES OF THE LIKE PRODUCT IN THE COUNTRIES

42. Explain how the selling prices are set (pricing methods) for the like product in the

domestic market by providing all the information relating to the terms and

conditions of sale in terms of:

Delivery Terms: OEMs, Wholesaler, Retailer, .....etc.

Payment: In Advance, upon delivery, credit (specify no. of days) ......


discount, .....

After-sales: Warranty, Maintenance contract, ....

Other (if any)




44. Complete the table in Attachment (4-9) for all domestic sales of the like product

during the period of investigation. Provide clear (PDF-format and hard) copies

for all domestic invoices for each domestic shipment of the like product.

Furthermore, attach (PDF-format and hard) copies of all domestic sales related

documents for 5 domestic invoices of the like product.


charges incurred after the ex-factory price on domestic sales in the countries

concerned. Provide evidence and working papers to explain each adjustment for 5

invoices.

46. Explain your company’s channels of distribution on the domestic market for the

like product starting from the factory gate up to the first resale to independent

customer. Describe the sales process for each method or channel of distribution

described and provide a detailed flow chart indicating all details (i.e. terms of

sale, pricing, customers) in Attachment (4-10).

18




47. Explain the relationship between your company and your customers (OEM’s,

wholesalers, retailers,..etc.) mentioned in the reply to Attachment (4-9) and

provide enough details for that in Attachment (4-11) including list of customers’

categories (i.e. OEMs, Distributors, Retailers, End-users), selling activities

performed in details.

Refer to definition of "affiliated person" in Annex 2.

48. Explain each step in the sales negotiation process of the like product starting from

contacting with the domestic customer (purchase order) up to the delivery of the

like product to this customer. Provide flow chart indicating all details in

Attachment (4-12).



reasons for that.

50. Please provide copies of contracts (with English translation) between your

company and your domestic customers for domestic sales in the countries

concerned (either long-term or short- term), describe in detail the process by

which the contracts, the prices, expenses, and quantities therein, are agreed to.

Describe each type of contracts applicable to the like product, including the

terms, the requirements for a price change or re-negotiation by either side, etc.

51. Are the prices of the like product that your company charges in the countries

concerned:

i) Subject to direct or indirect reimbursement to your domestic market

customers (e.g. sales promotion, advertising, warranty, etc)? or

ii) Influenced by a commercial agreement or relationship (including

mutual corporate affiliations and/or common shareholding)? or

iii) Inclusive of any consideration other than price?

If the answer to (i), (ii) or (iii) above is “yes”, please provide details.

19

EXPORT SALES OF THE LIKE PRODUCT TO THIRD COUNTRIES

52. Explain how the selling prices are set (pricing methods) for export sales to third

countries by providing all the information in terms of:

Delivery Terms: FOB, CIF, .....

Payment: in advance, upon delivery, credit (specify no. of days).....


discount, .....

After-sales: Warranty, Maintenance contract, ....

Other (if any)




54. Complete the table in Attachment (4-14) for all export sales of the like product

to third countries during the period of investigation. Because export sales to third

countries might be too many, you are requested to provide (PDF-format and hard

copies) for representative 5 export invoices of the like product exported to each of

the third countries and copies of the related export documents for only 5 export

invoices.


charges incurred after the ex-factory price on export sales to third countries.

Provide evidence and working papers to explain each adjustment for 5 export

invoices of the like product to third countries.

56. Explain your company’s channels of distribution to third countries for the like

product starting from the factory gate up to the first independent customer in third

countries. Describe the sales process for each method or channel of distribution

described and provide a detailed flow chart indicating all details in Attachment

(4-15).

21




57. Explain the relationship between your company and your customers (OEMs,

wholesalers, retailers,..etc) mentioned in the reply to Attachment (4-14) and

provide enough details for that in a similar attachment as indicated in

attachments (4-6 & 4-11) including list of customers’ categories (i.e. OEM’s,

Distributors, Retailers, End-users), selling activities performed in details.

58. Explain each step in the sales negotiation process of the export sales of the like

product to third countries starting from contacting with the customer in the third

country (purchase order) up to the delivery of the like product to this customer.

Provide flow chart indicating all details in Attachment (4-16).



reasons for that.

60. Please provide samples for copies of contracts between your company and your

customers for export sales to third countries (either long-term or short- term),

describe in detail the process by which the contracts, and the prices, expenses,

and quantities therein, are agreed to. Describe each type of contracts applicable

to the like product, including the terms, the requirements for a price change or re-

negotiation by either side, etc.

5. PURCHASES AND STOCKSPURCHASES

61. In case your company purchased the product under investigation or the like

product from other origins, please indicate in Attachment (5-1) the names of the

suppliers and the reasons for these purchases.

62. Provide invoices’ statement for the purchases of the product under investigation

or the like product and copies of purchase invoices in Attachment (5-2).

22

63. In case your company purchased raw materials or energy or other services related

to manufacturing from related companies or from companies in which capital you

contribute, please provide a list of the names of those companies with a

description of the nature of the relationship between your company and its

associated companies included all inter-companies transactions, indicating how

purchase prices of raw materials from these companies are determined.

Furthermore, please provide invoices’ statement for the purchases of these

materials from related companies.

64. Please complete Attachment (5-3) regarding the purchase of raw materials.

STOCKS

65. Provide a description of the stock of Raw materials, Semi-finished, and Finished

goods for the period of investigation related to the product under investigation

and the domestic like product and the exported like product to third countries in

Attachment (5-4).

23

6. PRODUCTION AND COST OF PRODUCTION

6-1 PRODUCTION

66. Complete the table in Attachment (6-1) related to the actual production in

volume for the product under investigation and the like product during the period

of investigation. In case your company manufactures the product under

investigation and the like product in more than one factory, please complete this

table separately for each factory.

67. Indicate in Attachment (6-2) the number and the names of your company’s

factories which produce the product under investigation or the like product.

68. Indicate the main inputs’ materials of the production process, whether such

materials were imported, and whether the input value includes import charges and

indirect taxes for both exported and domestic types.

6-2 COST OF PRODUCTION

69. Describe the cost accounting system used by your company to record and allocate

the production cost of the product under investigation (e.g. job costing, process

costing).

70. If your company uses a standard cost system state whether standard costs were

used in your response and whether all variances between standard and actual

costs have been allocated. Explain in detail the allocation method used, as well as

any significant or unusual cost variances that occurred during the investigation

period.

71. Please indicate the cost centers (direct & indirect) and the allocation methods

used regarding the product under investigation.

72. Describe the method used under your company's cost accounting system to

account for byproducts and scrap generated at each stage of the production

process.

24

73. Does your company receive, either directly or indirectly, any consideration from

a central or provincial Government or other organization (e.g., subsidies export

incentives, etc.) for the products you manufacture and sell? If so, please provide

details of any assistance on a per annum basis or on per unit basis, as appropriate.

74. Provide a copy of the income statement for the product under investigation for the

last 2 financial years including the period of investigation in Attachment (6-3).

Please provide full details of any allocation method used.

75. Please provide the cost of production of the product under investigation for

Domestic sales, Export sales to GCC, and exports to countries other than GCC in

Attachments (6-4), (6-5) and (6-6) respectively.

a- Separate schedules should be provided showing the cost structure for

each Type/Model (PCN) of the product under investigation and the like

product for the period of investigation. This should include the

following:

1- Identify and quantify the main raw material components and labour costs, and the basis of distribution/allocation of these costs to the product under investigation and like product during the POI.

2- Identify and quantify the indirect factory overhead costs and the basis of distribution/allocation of these costs to the product under investigation and the like product during the POI.

3- Identify and quantify the elements of SG&A costs, and the methods your company has used to allocate these costs to the product under investigation and the like product during the POI.

b- Attachments (6-4), (6-5), and (6-6) should be provided for each

type/model/ (PCN) of the product under investigation and the like

product.

c- Supporting documentation for the cost items and working papers

demonstrating the allocation of costs and expenses should be

attached.25

7. ATTACHMENTS

Attachment N0. Description Remark

1-1 Original power of attorney1-2 Articles of Association and related documents1-3 Business license1-4 Catalogues or Brochures about your company1-5 Overall organizational structure of your company

1-6 Related companies of your companyTable is attached

1-7 Shareholders of your companyTable is attached

2-1 Catalogues or brochures for the product under investigation

2-2 Types of the product under investigation Table is attached

2-3Differences between the product under investigation and the like products

Table is attached

3-1Audited Financial Accounts for the last 3 years including the POI for the company

3-2 Copy of Chart of Accounts3-3 List of Exchange Rate for domestic currency against US$

4-1 Total sales during the period of investigation Table is attached

4-2Studies about the product under investigation or the like product

4-3 Price lists for export to the GCC Countries during the POI

4-4Export sales of the product under investigation to the GCC Countries during the POI

Table is attached

4-5 Flow chart of Distribution Channels for exports to GCC

4-6Customers for the product under investigation to GCC during the POI

Table is attached

4-7 Flow chart of sales negotiation process for exports to GCC4-8 Price Lists for domestic sales

4-9 Domestic sales of the like product during the POI Table is attached

4-10 Domestic Flow chart of Sales process& Distribution Channels

4-11Domestic customers who sell the like product in your domestic market during the POI

Table is attached

4-12 Domestic flow chart of sales negotiation process4-13 Price lists for export to third countries during the POI

26

4-14 Export sales to third countries during the POI Table is attached

4-15 Flow chart of distribution channels for sales to third countries

4-16Flow chart of sales negotiation process for sales to third countries

5-1Suppliers for purchase of the product under investigation or the like product

Table is attached

5-2Invoices statement for the purchases of the product under investigation or the like product

Table is attached

5-3 Purchase of Raw materials Table is attached

5-4 Stock of raw materials, work-in-process, and finished goods Table is attached

6-1Actual production in volume for the product under investigation and the like product during the POI

Table is attached

6-2Your company’s factories producing the product under investigation

Table is attached

6-3 Income statement for the product under investigation the POI Table is attached

6-4Factory Cost and Profit for Domestic Sales of the Like Product.

Table is attached

6-5Factory Cost and Profit for Export Sales of Product under Investigation to the GCC.

Table is attached

6-6Factory Cost and Profit for Export Sales of the Like Product to Third Countries (same country as reported in Att.4-17)

Table is attached

27

Attachment (1-6)

Affiliated companies

Name, address, phone, fax, email, and website of

related company

Please tick (√)

if involved in any way with the product

under investigation or

the like product

List

activities

Percentage of share-

holding in related

company

%

Percentage of share-holding

of related company in

your company

%

28

Attachment (1-7)

Shareholders of your company

websiteEmailFaxTelActivity of shareholder

%Share in the

capitalAddressNameNo.

1-

2-

29

Attachment (2-2)

Product Coding System

Remark

sPCNExport

sales

code

Domest

ic sales

code

Producti

on code

Description

*

Name of

Type/Mo

del

Provide explanations of the elements composing your company’s production and

sales codes.

* Description may include dimensions of each type/model.

Provide this table in EXCEL

30

Attachment (2-3)

Differences between the product under investigation and the like products

Like product

exported to third

countries

Like product in

the domestic

market

Product under

investigation

exported to GCC

Difference


31

Attachment (4-1)

Total Sales during the period of investigation

Unrelated CustomersRelated Customers

DataVolume (M2)ValueVolume (M2)Value

Total company’s Sales (all products) as in Income Statement1

Domestic market

Exports to GCC

Exports to other Countries

Sales of the Product Under Investigation

Domestic Market

Exports to GCC

Exports to other Countries In case the accounts of your company have been consolidated with related companies, prepare a separate table showing the consolidated turnover, after

all discounts and free of taxes, in the same format. Explain in detail how the consolidation has been done.

Specify currency


1 Net sales after all discounts.

32

Attachment (4-4)

Export sales of the product under investigation to the GCC Countries during the POI

Oth

er (S

peci

fy)

Ban

k ch

arge

sC

redi

t Cos

tW

arra

nty

com

mis

sion

sIn

land

Fre

ight

Pack

ing

Han

dlin

g

Dis

coun

t/Reb

ate

Mar

ine

Insu

ranc

e O

cean

Fre

ight

Paym

ent t

erm

1

Cur

renc

yT

otal

CIF

Val

ue

Del

iver

y te

rms

Invo

ice

Val

ue

Vol

ume

(squ

are

met

ers)

M2

PCN

Prod

uct

Des

crip

tion

as

Prod

uct N

ame

Typ

e/M

odel

Exp

ort S

ales

C

ode

Prod

uctio

n C

ode

Impo

rter

GC

C-

Cou

ntry

Impo

rter

Cod

e

Impo

rter

Nam

e

Exp

orte

r C

ode

Exp

orte

r N

ame2

Arr

ival

Por

t

Ship

ping

Por

t

Ship

ping

Dat

e

Invo

ice

Dat

e

Invo

ice

No.

Seri

al N

o.

1

2

3

4

…

Provide this table in EXCEL Specify currency Attach copies of export documents for 5 export invoices for the product under investigation. Attach evidence and working papers to explain each adjustment for 5 invoices.

1 In case of credit sales, specify the number of days in which payment is made.

2 In case your company is the exporting producer for the product under investigation, then write (Not Applicable or N/A).

33

Attachment (4-6)

Customers of the product under investigation exported to GCC during the POI

Website

Em

ail

Fax

Tel

Add

ress

Value Volume

(M2)

Nature of relationshipi.e. affiliated,

subsidiary, …etc)

Specify currency

34

Attachment (4-9)

Domestic sales of the like product during the POIO

ther

(Spe

cify

)

Cre

dit C

ost

Han

dlin

g

Pack

ing

Inla

nd F

reig

ht

Dis

coun

ts/R

ebat

es

Del

iver

y te

rms

Del

iver

y da

te

Paym

ent T

erm

s1

Cur

renc

y

Invo

ice

Val

ue

Vol

ume

- squ

are

met

ers (

M2 )

PCN

Prod

uct

Des

crip

tion

as in

In

voic

e

Prod

uct N

ame

Typ

e/M

odel

Cus

tom

er C

ode

Cus

tom

er N

ame

Prod

ucer

Nam

e2

Dom

estic

Sal

es

code

Prod

uctio

n co

de

Invo

ice

date

Invo

ice

No.

Seri

al N

o.

1

2

3

…

Attach copies for all related documents for 5 domestic sales’ invoices of the like product.


Specify currency

Attach evidence and working papers to explain each adjustment for 5 invoices.


2 In case your company doesn’t sell the product under investigation for other producers in the domestic market, then write (Not Applicable or N/A).

35

Attachment (4-11)

Domestic customers who sell the like product in your domestic market during the POI

website EmailFaxTelAddressValueVolume (M2)

Nature of relationship

(i.e. affiliated, subsidiary, …

etc)

Category (OEM,

Distributor, wholesaler,

Retailer, end-user)

Selling Activit

y

Country

Customer Name

and Code

Specify currency

36

Attachment (4-14)

Export sales of the like product to third countries during the POI

Pack

ing

Oce

an F

reig

htPa

ymen

t ter

m1

Cur

renc

y

Del

iver

y te

rms

Invo

ice

Val

ue

Vol

ume

- sq

uare

met

ers

(M2 )

PCN

Prod

uct

Des

crip

tion

as

in In

voic

ePr

oduc

t Nam

e T

ype/

Mod

elE

xpor

t Sal

es

Cod

ePr

oduc

tion

Cod

eIm

port

er

Cou

ntry

Rel

atio

nshi

p w

ith Im

port

er

or e

xpor

ter

Impo

rter

Cod

e

Impo

rter

Nam

e

Exp

orte

r C

ode

Nam

e2

Arr

ival

Por

t

Ship

ping

Por

t

Ship

ping

Dat

e

Invo

ice

Dat

eIn

voic

e N

o.

Seri

al N

o.

1

2

3

…

Attach copies of export documents for 5 invoices for the exported like product Provide this table in Excel Specify currency Attach evidence and working papers to explain each adjustment for 5 invoices.


2 In case your company is the exporting producer for the product under investigation, then write (Not Applicable or N/A).

37

Attachment (5-1)

Suppliers

Reasons for

purchase

Website

Email

Fax

Tel

AddressValue Volume

(M2)

Category (OEM,

Distributor,

wholesaler, Retailer, end-user)

Nature of relationship

(i.e. affiliated, subsidiary, …

etc)

Selling Activit

y

Country

Customer Name

and Code

Specify currency

38

Attachment (5-2)

Invoices’ statement for the purchases of the product under investigation or the like product

Country of origin

Customer codeRelationCustomer

namePayment

termsDelivery

termsInvoice Value

Volume- square meters

(M2)

Invoice date

Invoice No.PCNProduct

Description

Product Name

Type/ModelSales code

Seri

al N

o.

1

2

…

Provide this table in EXCEL Specify currency Attach copies of purchase invoices

39

Attachment (5-3)

Purchase of Raw Materials

Purchased domestically Imported without duties Imported with duties TOTAL

Raw Materials

Country of origin

Supplier Name

Relation (Related or Unrelated)

Value Volume Value CIF VolumeValue

CIFVolume

(+) Duty paid

(-) Duty

DrawbackValue Volume

Average cost per

unit

a)

b)

c)

d)

….etc

TOTAL

Provide this table in EXCEL Specify currency and unit of measurement for volume.

40

Attachment (5-4)

From (1st July 2017 to 30th June 2018)Data ValueVolume- square meters (M2)

Stock of raw materialsOpening stock: July 1st, 2017

Closing stock: June 30th, 2018

Stock of Semi-finished GoodsOpening stock: July 1st, 2017


Stock of Finished GoodsOpening stock: July 1st, 2017


Stock during the POI related to the product under investigation and the domestic like product and the exported like product to third countries

Provide these Table in EXCEL

Specify Currency

41

Attachment (6-1)

Actual production during the POI

From (1st July 2017 to 30th June 2018)Data

Production CostVolume- square meters (M2)

Total production of all products

Total production of the product under investigation

Total production of the exported product under

investigation to the GCC

Total production of the like product for domestic sales

Total production of the like product for exports to all

third countries

Provide this Table in EXCEL

Provide this Table for each factory.

42

Attachment 6-2

Your company’s factories producing the product under investigation

Production in volume

(square meters) (M2)TelCountry City AddressFactory name


43

Attachment 6-3

Income statement for the product under investigation in the last two years including the POI

Total all productsDomestic market sales

during period of investigationExport market (GCC + other)

Sales during period of investigationUnrelated customers Related customers Unrelated customers Related customers

Last Financial

Year

Period of Investigation

(POI)

Product under

Investigation

Other Products

Product under

Investigation

Other Products

Product under

Investigation

Other Products

Product under

Investigation

Other Products

Total Quantity of Sales (M2)

Net Value of Sales

Cost of goods sold

Selling, General, and Administrative Expenses

(SG&A) *Financing Expenses

Total costs

Net Profit/Loss Before Tax

Net sales revenue is the sales revenue as per the income statement (after all discounts or sales returns or allowances). All values must be given for each column separately. Identify all SG&A elements. Specify the Currency Provide these Tables in EXCEL

44

Attachment 6-4

Factory Cost and Profit for Domestic Sales of the Like Product during the POI

Cost Element Per M2 Product (1) Type/Model

Product (2) Type/Model


PCN (1) PCN (2) PCN (3)1) Direct Materials

a) ………b) ……….c) ……....d) Others (Please Specify)

2) Direct Labour

3) Manufacturing Overhead

- Indirect materials - Indirect labour - Energy costs - Depreciation- Maintenance and repairs - Packaging Costs- Packaging Costs1 - Others (Please Specify) 4) Total Manufacturing Cost

(1+2+3)

5) Selling, General and Administrative Expenses (SGA)

- Insurance- Inland freight- Commissions- Advertising- R&D- Others (Please Specify)

6) Financing Expenses

TOTAL COST OF PRODUCTION (4+5+6)Net Profit/Loss before Tax

Selling Price Ex-Factory

Lines may be added to reflect the company’s cost structure.

The cost data above must be provided for each (PCN) of the domestic like product. This information must also be provided in EXCEL Specify Currency.

-Packaging Costs

1 If the packing process is part of the manufacturing process detail it here, otherwise it should be included in the selling expense.

43

Attachment 6-5

Factory Cost and Profit for Export Sales of Product under Investigation to the GCC during the POI






2) Direct Labour



(1+2+3)





Selling Price Ex-Factory

Lines may be added to reflect the company’s cost structure. The cost data above must be provided for each (PCN) of the domestic like product. This information must also be provided in Excel. Specify Currency.

-Packaging Costs


44

Attachment 6-6

Factory Cost and Profit for Export Sales of the Like Product to Third Countries during the POI






2) Direct Labour



(1+2+3)





Selling Price Ex-Factory Lines may be added to reflect the company’s cost structure.

The cost data above must be provided for each (PCN) of the domestic like product. This information must also be provided in EXCEL Specify Currency.

-Packaging Costs


45

8. ANNEXS

ANNEX 1: CERTIFICATE

The undersigned on behalf of (name of company) certifies that all information

supplied in this questionnaire is correct and complete accordingly to records of the

company,

And in case of differences between the information submitted and those recorded in

you company, the GCC-TSAIP has the right to disregard this information,

And understands that the information submitted in this questionnaire or any

information submitted during the investigation proceeding may be subject to audit and

verification by the GCC-TSAIP.

Date signature of authorized official

Company stamp name and title of authorized official

46

ANNEX 2: GLOSSARY

WTO Agreement on Implementation of Article VI of the General Agreement on Tariffs and Trade 1994

Antidumping agreement

The GCC Common Law on Anti-Dumping, Countervailing and safeguard measures

The GCC Common Law

Exporting a product to GCC Member States at less than its normal value in the ordinary course of trade for the like product in the exporting country.

Dumping:

Injury shall mean material injury to a GCC industry, threat of material injury to a GCC industry or material retardation of the establishment of such an industry.

Injury

Causal relationship between the dumped imports and the injury to the GCC industry. It should be determined on the basis of examination of all relevant evidence. The investigation authority will take actions only against the dumped imports which cause injury to the GCC industry. The injury caused by other factors must not be attributed to dumped imports.

Causal link

The price paid or payable for the product under investigation when sold for export from the exporting country to the GCC market

Export price:

The price paid or payable, for the like product in the ordinary course of trade when destined for consumption in the exporting country

Normal value:

The difference between the normal value and the export price during the period of investigation

Dumping amount:

Percentage of dumping amount relatively to the export priceDumping margin

A fair comparison has to be made between the export price and the normal value. Due allowances have to be made in each case, on its merits, for differences which affect price comparability, including discounts, rebates and quantities, transport, insurance, handling, loading and ancillary costs, packing, credit, after-sales costs, commissions.

Adjustments

It shall be considered to be de minimis if the dumping margin is less than two percent (2), expressed as a percentage of the export price. In this case the investigation shall be terminated

De minimis

The imported product as described in the notice of initiation of Product under 47

the investigation. investigation:

GCC products which are identical or alike in all respects to the product under investigation, or in the absence of such a product, another product which, although not alike in all respects, has characteristics closely resembling those of the product under investigation

Like products:

GCC Industry: Member States’ producers as a whole of the like products or those of them whose collective output of the products constitutes a major proportion of the total domestic production of those products. For the purpose of safeguard investigations, the term GCC industry shall mean total Member States producers as a whole of the like or directly competitive products operating within the territory of Member states, or those whose collective output of the like or directly competitive products constitutes a major proportion of the total domestic production of those products.

GCC Industry:

Bureau of the Technical Secretariat of Anti-injurious Practices in International Trade

GCC Competent authority

Combined markets of the GCC Member States.GCC market:

Buyer(s) without association, and without a commercial or production partnership with the importer in the importing country or with the exporter or producer in the exporting country, and without any relationship with them, or where both of them are not controlled by a third party directly or indirectly and where neither of them are members of same family.

Independent buyer(s):

Under relevant trade laws, transactions between affiliated persons are subject to particular scrutiny. Affiliated persons (affiliates) include (1) members of a family, (2) an officer or director of an organization and that organization, (3) partners, (4) employers and their employees, and (5) any person or organization directly or indirectly owning, controlling, or holding with power to vote, five percent or more of the outstanding voting stock or shares of any organization and the organization. In addition, affiliates include (6) any person who controls any other person and the other person, and (7) any two or more persons who directly control, are controlled by, or are under common control with, any person. “Control” exists where one person or organization is legally or operationally in a position to exercise restraint or direction over the other person or organization.

Affiliated Person(s):

48

An arms-length transaction is a voluntary sale involving two parties who are independent of each other. In such a transaction no special consideration, such as preferred pricing arrangements, special services, etc., is made because of one party’s relationship to the other. Sales within a company, or other transactions between two parties having some legal, financial, or other common connection, are not considered to be arms length transactions.

Arms-Length Transaction:

In order to establish whether differences in levels of trade exist, the GCC-TSAIP reviews distribution systems, including categories of customers, selling activities, and levels of selling expenses for each type of sale. Different levels of trade are typically characterized by purchasers at different stages in the chain of distribution and sellers performing qualitatively and/or quantitatively different selling activities. Different levels of trade necessarily involve differences in selling activities, although differences in selling activities alone are not sufficient to establish differences in levels of trade. Similarly, customer categories such as OEM’s, distributor, wholesaler, retailer, and end-user are often useful in identifying levels of trade, although they, too, are insufficient in themselves to establish differences in levels of trade. Rather, the GCC-TSAIP evaluates differences in levels of trade based on a seller’s entire marketing process.

A level of trade adjustment may be granted where a company can show that its domestic sales of the like product are being made at a level of trade different from the level of trade of its export sales and that such difference has affected price comparability. For this purpose, any claims should clearly identify the domestic and export levels of trade by demonstrating that functions and prices for the sales in question are shown to be appropriate to the alleged levels of trade on both markets.

Level of Trade

Period of investigation during which should be determined the existence of dumping, injury and causal link between them.

POI

The GCC-TSAIP may carry out on-spot visits to examine the records of the company and to verify the information provided in this questionnaire

On-spot visit

The commitment given by the interested party that information submitted in the questionnaire are correct and complete

Certificate

49

ANNEX 3: GUIDE FOR ADJUSTMENTS

In order to carry out a fair comparison between the export price and the normal value of the product concerned the following information is requested. Where the normal value and the export price as established are not on a comparable basis due allowance, in the form of adjustments, can be made where prices and price comparability are affected. For this purpose you may claim adjustments where it can be demonstrated that the factor concerned is one which has resulted in a different price being charged to your customers.

Please note that all allowances either in Export or Domestic Sales must have already been included in the cost of production. For example, an adjustment you may report for packing cost or customs charges must have already been included in the cost of production as a component of COM or SG&A.

1. Adjustments on Export sales You are requested to explain in detail each adjustment you claim. Report the amounts of the adjustments on a transaction-by-transaction basis in the listings provided in Attachment (4-4). Wherever possible, report actual expenses rather than averages. If you allocate any of these expenses, explain the reason for your choice and the methodology used.

a- Discounts and rebates

Describe in detail your policy for granting discounts and rebates to customers in GCC. List all the different kinds of discounts or rebates you have granted, e.g. cash discounts, quantity discounts, loyalty discounts, year-end rebates etc. and describe their terms. Include deferred discounts. If discounts or rebates vary by class of customer, explain separately the discounts and rebates given to each class.

Provide your discount schedules, and be prepared to furnish on request contracts or agreements that reflect all discounts and rebates that were given.

Note that the term "rebate" includes credit on current or future purchases, promissory notes, extension of credit, or free goods or services. Also note that any claim should be properly quantified and directly linked to the sale under consideration.

b- Transportation, insurance, handling, loading, and ancillary costs

List all charges which are included in the export prices such as custom charges, port charges and expenses, storage charges at ports, and explain how you have quantified each of these charges. Report the adjustments in Attachment (4-4) transaction-by-transaction table using separate columns for each cost.

Make necessary adjustment for transportation costs which were incurred subsequent to the sale being made, for moving the products from the production premises to the independent customer.

50

c- Packing costs

Specify the cost of packing for the product under investigation. List material and labour costs separately. Be specific in describing packing materials and any special or extraordinary procedures used in preparing the product under investigation for shipment to GCC. If the product under investigation is subsequently repackaged in GCC, report these charges and costs separately.

d- Cost of any credit granted for the sales

Credit refers to the cost of the time the buyer is given to pay the goods, i.e. agreed in the terms of payment. Describe the method you have used to calculate the credit costs. Indicate the interest rate you used to compute expenses associated with granting credit on sales. Provide information on interest rates you paid for short-term borrowings for the currencies concerned.

For credit cost for terms of payment like CAD (Cash against Document), L/C at Sight or etc, you are required to reflect period between time of loading and time of payment into Term of Payment.

e- Direct costs of providing warranties, technical assistance and services, as provided for by law and/or in the sales contract

List all direct costs mentioned above which were incurred and were specified in the export sales contracts, or were required by the law of the country concerned. Identify the general ledger account(s) where each expense is located.

f- Bank charges

List all banking expenses incurred due to the export sales.

g- Commissions paid in respect of the sales under consideration

Where commissions were paid to unrelated or related sellers, report the amount of commission expenses and explain the terms under which commissions are given.

h- Import charges or indirect taxes

An adjustment concerning import charges and taxes can be made under the conditions set out in Article 2.4. of the Anti-Dumping Agreement. For such adjustments provide the following information.

51

Duty Drawback (If any)

An adjustment concerning import charges can be made. For such adjustments provide the following information.

i. Provide original and English translations of statutes and regulations authorizing duty drawback on exported goods and governing the methods used to calculate duty drawback.

ii. Report separately the total amount of duty drawback you received for your sales to GCC.

iii. Explain the method you used to connect the duty drawback amount to the specific sales to GCC.

iv. Report in the transaction-by-transaction listing Attachment (4-4) the amount of duty drawback you received for each sale transaction to GCC.

v. Explain how you calculated this amount.

vi. Provide for two export invoices, all necessary information with photocopies of the original documents (the documentation which was submitted to claim the refund) that justify the adjustment you claim and explain how you calculate the amount that you report in the transaction-by-transaction listing.

vii. Explain in particular the relation between the amount received from the Government when you export with the amount paid for imported materials.

Indirect taxes (If any)

An adjustment concerning indirect taxes can be made. For such adjustments provide the following information.

i. List all internal taxes imposed on the domestic market products, which were either rebated upon exportation or not collected on the products exported to GCC.

ii. For each tax listed above, provide original and English translations of statutes and regulations authorizing the collection of the tax, including documents that explain the method of calculation, assessment, and payment of the tax.

52

iii. For each tax listed above, separately provide information on the tax base or taxable price, the tax rate, the amount of taxes assessed, any deductions or offsets to the tax and the formula used to calculate the tax amount.

iv. Indicate when you are legally obligated or liable for tax payment. Report when you actually paid taxes and whether you maintain separate accounts for these taxes.

v. If any, report in the transaction-by-transaction listing Attachment (4-4) the amount of such taxes applicable to each domestic sale but rebated or not collected for sales to GCC and provide the relevant documents. Please specify the currency used.

vi. Explain how you calculated this amount.

i- Other factors Any adjustments should also be made for differences in other factors, not provided in the above paragraphs, if it is clearly described and demonstrated that they affect price comparability. If you claims allowances in “Other 1” and “Other 2” in any transaction, please list the type of claims, explain why they are important and provide supporting document and calculation sheet. Identify the general ledger account(s) where each expense is located.

Report all such expenses incurred for exports to the GCC market in the transaction-by-transaction Attachment (4-4). Please specify the currency used.

2. Adjustments on Domestic sales You are requested to explain in detail each adjustment you claim. Report the

amounts of the adjustments on a transaction-by-transaction basis in the listings provided in Attachment (4-9). Wherever possible, report actual expenses rather than averages. If you allocate any of these expenses, explain the reason for your choice and the methodology used.

Any adjustment can be claimed for where it can be demonstrated that the factor concerned is one (relevant documents and calculations must be provided for this purpose, otherwise allowance claims may not be taken into consideration), which has resulted in a different price being charged to your customers.

a- Discounts and rebates, including those given for differences in quantities

- Describe in detail your policy for granting discounts and rebates to independent domestic customers. List all the different kinds of discounts or rebates you granted, e.g. cash discounts, quantity discounts, loyalty discounts, year-end rebates etc. and describe their terms.

53

- Include deferred discounts. If discounts or rebates vary by class of customer (e.g. users and distributors), explain separately the discounts and rebates given to each class.

- List all of your customers who were eligible for each discount or rebate program and their customer codes, and describe the criteria you used to determine their eligibility.

- Provide your discount schedules and be prepared to furnish on request contracts or agreements that reflect all discounts and rebates that were given.

- Note that the term "rebate" includes provision of either currency, credit on current or future purchases, promissory notes, extension of credit, or free goods or services.

- Also note that any claim should be properly quantified and directly linked to the sale under consideration.

b- Cost of any credit granted for the sales

Cost of credit refers to the implicit cost of granting credit for a specific sales transaction. The agreed terms of payment must be known to the parties involved and the cost of the credit terms must be reflected in the sales price of the like product. Describe the method you have used to calculate the credit costs. Provide information on interest rates applied or applicable to your company for short-term borrowings during the investigation period. Credit cost may only be claimed if it is proved that parties involved have known term of payment during the time of sales and this cost has been reflected into sales seen in commercial invoice itself, or other substantiated documents.

c- Packing costs

Specify the costs of packing for the products shipped to domestic customers and those shipped to GCC. List material and labor costs separately. Be specific in describing packing materials and any special or extraordinary procedures used in preparing the like product. Identify the general ledger account(s) where each expense is located.

d- Transportation, handling, loading costs

List all charges included in domestic prices and explain how you have quantified each of these charges.

54

Make necessary adjustment only for transportation costs incurred subsequent to the sales, for moving the products from the production premises to the independent customer. Identify the general ledger account(s) where each expense is located.

e- Level of trade

An adjustment for differences in levels of trade, including any differences which may arise in OEM sales, can be made where, in relation to the distribution chain in both markets, it is shown that the export price, including a constructed export price, is at a different level of trade from the normal value and the difference has affected price comparability which is demonstrated by consistent and distinct differences in functions and prices of the seller for the different level of trade in the domestic market of the exporting country. The amount of the adjustment has to be based on the market value of the difference.

However, in circumstances not envisaged in the paragraph above, when an existing difference in level of trade cannot be quantified because of the absence of the relevant levels on the domestic market of the exporting country or the importing country, or where certain functions are shown clearly to relate to levels of trade other than the one which is to be used in the comparison, a special adjustment may be established.

j- Other factors Any adjustments should also be made for differences in other factors, not provided in the above paragraphs, if it is clearly described and demonstrated that they affect price comparability. If you claims allowances in “Other 1” and “Other 2” in any transaction, please list the type of claims, explain why they are important and provide supporting document and calculation sheet. Identify the general ledger account(s) where each expense is located.

Report all such expenses incurred for sales in the domestic market in the transaction-by-transaction Attachment (4-9). Please specify the currency used.

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ANNEX 4: GUIDELINES FOR COMPLETING THE NON-LIMITED DATA

To protect confidential information, the following instructions show you how to complete the non-limited data:

When the information concerns numbers for various years you can use indices.Example of limited information:

2013 2014 201530000 60000 80000

The non-limited version could be as follows:2013 2014 2015100 200 267

When the limited information concerns text you can either summarize it or eliminate the names of parties by indicating their function.

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