| 10/10/2006||Sweden||Disagreement with proposal|
| 9/15/2006||United Kingdom||We agree with all the recommendations made by the AEG.|
| 9/15/2006||Latvia||After deep discussions and expert consultations we basically support the
1993 SNA Update Issues.|
| 9/15/2006||Norway||We support the views of the AEG regarding all non-resident SPEs should be classified as separate institutional units. We do however not like the use of the word SPE (Special Purpose Entities). SPE relate to different institutional sector classifications and should not be merged in the discussion of sector classi¬fi¬cation. We would also point out that the use of SPE could contribute to misunderstandings, for instance, mixing up SPE and SPV. |
The description of holding corporations in the new SNA is not finalized and Statistics Norway support further discussions. Statistics Norway is of the opinion that holding companies for a non-financial group should not be moved out of non-financial to financial corporations, because they are neither engaged in financial intermediation nor provide financial auxiliary services.
We support the distinction between i) Parent corporations and ii) Holding corporations. There are however some confusion regarding classification of parent corporations. Our question is whether, in the new SNA, the parent corporations should be classified according to their own activity or according to the main activity to their subsidiary companies.
We support the proposal to create a third sub-grouping of other financial institutions (holdings, brass-plate entities, empty shells).
Statistics Norway supports also a more extensive use of boxes where terms like financial corporations, financial intermediation, monetary financial intermediation, investment funds, miscellaneous financial intermediation and financial auxiliaries are explained. We also support the new table, which provides an overview of the various groupings of institutional units classified as financial corporations.
| 9/14/2006||Bank of Lithuania||We agree with the AEG recomendations.|
| 7/27/2006||Egypt||These units should be treated as ancillary units and merged with their related enterprises unless it is located outside the country (different economic territory).|
| 7/25/2006||Central Bank of Costa Rica||We find it very necessary to include in the statistical manuals definitions and other elements aimed to identify these types of units, because there is a wide variety of them and they should be recognized in the same way by all national accounts compilers. We agree with the recommendations of the AEG. |
| 12/13/2005||Canada||Canada’s view is that the BOPCOM view serves the statistical system well. A Unit incorporated in another territory to do transactions which create a liability for the government should be viewed as carrying a loan. This way the resident government still has the liability on its balance sheet. No exceptions need to be made for treatment of units incorporated in other countries under the BOPCOM view.|
| 12/1/2005||Norway||We support the views of the AEG regarding that all SPEs should be separate institutional units when the SPEs are in a different economic territory to that of their owners. |
We are however of that opinion that holding companies for a non-financial group should not be placed as a sub-sector of financial corporations when the holding company operates in the same economic territory as the rest of the company group.
We do not like the use of the word SPE (Spesial Purpose Entities). SPE relate to different institutional sector classifications and should not be merged in the discussion of sector classification. We would also point out that the use of SPE could contribute to misunderstandings, for instance mixing up SPE and SPV.
| 11/29/2005||Tadjikistan||Мы согласны с тем. что вспомогательные корпорации и ЕСН можно рассматривать как отдельные институциональные единицы, если их резидентство и отнесение к институциональному сектору иные, чем у компании-владельца. На самом деле, подобная ситуация предусмотрена в СНС в отношении зарубежных отделений корпораций, банков или подразделений предприятий, предоставляющих нерыночные услуги своим работникам.|
| 11/29/2005||Estonia||Clear guidelines needed for the treatment and classification of the holding companies as regards the ongoing revision of ISIC/NACE.|
| 6/30/2005||Slovak Republic||We agree with AEG recommendations in issues of treatment of multi-territory enterprises, holding companies and special purpose entities as well as with criteria for recognition of branches.|
| 6/30/2005||Serbia and Montenegro||We agree with the recommendations made at the December 2004 meeting of the AEG.|
| 6/3/2005||Central Bank of Venezuela||We agree to the treatment of such entities as separate institutional units resident in their country of incorporation, considering among the criteria for classification the country of incorporation or legal domicile, although it is advisable to provide a more complete definition of terms such as "country of incorporation" and "legal domicile." |
We believe it is appropriate to provide an international, standard definition for Special Purpose Vehicles (SPVs).
| 5/19/2005||Bank of Indonesia||Related with item no. 16 [issue 38a], 18 [issue 39b], and 19 [issue 25bii], the treatment of holding companies, SPEs, and trusts should consider with the specification of economic territory.|
| 5/19/2005||Swiss National Bank||We agree to the three recommendations by BOPTEC and DITEC:|
i) SPEs should be treated as separate institutional units
ii) SPEs should be classified according to the territory of incorporation or legal domicile
iii) Lacking a common definition for the time being, we also support the proposal that SPEs are identified separately by the country of legal domicile of SPEs. Efforts to find a common definition should be continued in order to facilitate international and bilateral comparisons.
| 5/18/2005||Central Bank of Chile||We agree to the treatment of such entities as separate institutional units. In Chile, these entities are self-classified for tax purposes, primarily in two sectors: as investment companies (financial intermediation) or real estate companies (real estate services). However, in a small number of cases, holding companies classified in trade or other activities in which their predominant center of economic interest lies have also been detected. |
We thus share the conclusion that further discussion is needed to address the issue of sector classification or the standard definition. It is also reasonable to postpone the definition of residence of these companies until the definitions of residence also currently under discussion are resolved in preparing a new Manual.
| 5/16/2005||Croatian National Bank||We agree that SPEs should be treated as separate institutional units, but it is necessary to provide unified, clear and comprehensive statistical guidelines on identification and treatment of these entities. In this sense, it is necessary to update BPM-5.|
| 5/16/2005||Jordan||DOS agree that SPE should be treated as separate institutional units and support developing indicative guidelines on the identification of SPEs in the balance of payments manual and SNA.|
| 5/16/2005||Eastern Caribbean Central Bank||We agree that Special Purpose Entities incorporated in an economic territory other than any of its owners should be treated as a separate economic unit and as a resident in the country of its incorporation. We would welcome the provision of guidelines on the identification of SPEs.|
| 5/13/2005||National Bank of Kazakhstan||We consider that Special Purpose Enterprises incorporated in one economy other than any of its owners should be treated as a separate institutional unit and resident in its country of incorporation.|
| 5/12/2005||European Central Bank||ECB does not necessarily support the conclusions. In our view, the decisions taken on the treatment of holding companies, SPEs and trusts are premature as the subject should be treated in the context of item 25 as a whole. |
| 5/12/2005||Bank of Thailand||We think that SPE and holding company should be viewed as a separate institutional unit from the affiliated company it controls or serves IN ALL CASES (whether or not it is located in the same economic territory as its affiliate/parent company).|
| 5/10/2005||USA||The U.S. Bureau of Economic Analysis endorses the recommendations made by the AEG.|
| 5/10/2005||National Bank of Moldova||We agree with the concept that an SPE incorporated in an economic territory other than any of its owners should be treated as a separate institutional unit and as a resident in the country of its incorporation. We consider that a broader definition of SPE according to the international standards is needed.|
| 5/9/2005||Australia||Australia agrees with the AEG recommendations|
However, the ABS notes that this decision deals with only one case of SPEs and that discussion is continuing in the context of BOPCOM on the treatment of more complex cases. The relationship of this discussion to the discussion of the treatment of holding companies in the context of the revision of ISIC is noted.
| 5/9/2005||Maldives||Holding company is quite common when a parent corporations sets up several subsidiaries, associates corporation. To facilitate financing of the different corporation, a holding company is set up to attend to managing the investments. The holding company therefore produces management services to the entire corporation. The question is how to treat this holding company. We wish to agree with the AEG that there should be indicative guidelines on the identification of holding companies and special purpose enterprise. How to classify the economic activity of the holding company and the treatment of the expenses if these are distributed to the corporation also needs to be outlined for consistency. (And provide specific examples particularly in developing countries)|
| 5/9/2005||United Kingdom||The recommendation that an SPE incorporated in an economic territory other than that of any of its owners should be treated as a separate institutional unit and resident in its country of incorporation should not reach closure at this stage. The issue of non resident government-owned SPEs is of huge importance in determining measures of debt, and we feel strongly that your recommendation that the issue should be coordinated with the TFHPSA before closure should be followed. This is necessary to keep and clarify as a primary classification criterion the concept of 'institutional unit' (in close relation with the criteria on control and SPE). Our current understanding is that THPSA are still discussing these issues and are yet to reach agreement. And it is more than likely that they may reach a different position from that reached by the BPM5 revision taskforces. We therefore think it is essential that the issue should not be closed until fully discussed and agreed by both BOPCOM and TFHPSA.|
| 5/9/2005||Central Bank of Iran||We support the views of the AEG that SPEs should be treated as a separate institutional unit.|
| 5/6/2005||Turkey||We agree with the recommendations made by the Advisory Expert Group on National Accounts at its second meeting in December 2004.|
| 5/6/2005||Commonwealth of Independent States ||We agree that ancillary corporations and SPE can be treated as a separate institutional unit when it has different residency and institutional sector than the owner. In fact, similar situation is envisaged in the SNA in respect of foreign divisions of corporations, banks or divisions of enterprises providing non-market services to employees.|
| 5/6/2005||Macao, SAR China||We agree with the recommendations.|
| 5/5/2005||Sweden||In principle we support the recommendation of the AEG. |
We fully support the recommendation on SPEs incorporated in an economic territory other than any of its owners should be treated as a separate institutional unit and resident in its country of incorporation.
We would also emphasize the need for an international harmonized definition of SPEs and guidelines to their classification of institutional sector.
We have also noticed that relations might exist between the ongoing revision of ISIC/NACE and the SNA Revision as regards the financial corporations sector (SNA 4.79) and the treatment and classification of holding companies, SPEs, trusts and other portfolio investment units.
| 5/4/2005||Denmark||Statistics Denmark supports the proposal that a special purpose entity incorporated in an economic territory different from its owners should be considered a separate institutional unit in the country of incorporation, even if it is an ancillary corporation and ,as such, would not be treated as a separate unit, if incorporated in the same country as its parent corporation.|
| 4/29/2005||Norway||Statistics Norway supports the views of the AEG.|
| 4/29/2005||Central Bank of Colombia||El Banco de la República de Colombia esta de acuerdo con la adopción de los conceptos sugeridos en las preguntas relacionadas con las SPEs, pues estos permitirán mejorar las estadísticas y facilitar la comparación entre países.|
| 4/28/2005||Trinidad and Tobago||We agree with the recommendations of the AEG.|
| 4/25/2005||Bank of Sierra Leone||With reference to the above subject we agree with the recommendations of the Expert Group on National Accounts (AEG) especially where there is harmonization of definitions and other concepts between the Balance of Payments (BOP) and system of National Accounts (SNA).|
| 4/18/2005||Netherlands Antilles||It is desirable to have more guidelines on the identification and treatment of these entities. |
The international financial sector in the Netherlands Antilles consists of trust companies (companies that are responsible for the administration of the offshore companies), offshore banks, and individual "offshore" enterprises with employees. Only those companies who have an "offshore" permit and have at least one person on their payroll for at least 15 hours per week are regarded as resident enterprises. The other enterprises are regarded as non-resident because there is no physical production of goods and services and inclusion of the production in the GDP would not reflect the domestic production in the Netherlands Antilles.
Depending on our resources we will construct a satellite account for these units in which they will be treated as separate institutional units.
| 4/14/2005||Bank of France||En ce qui concerne le traitement des unités institutionnelles (25b), il nous parait important de rappeler que la définition des ces unités repose sur un certain nombre de critères – notamment l’existence de comptes séparés et l’autonomie de décision- et ne saurait donc résulter du seul critère de résidence. Dans ce contexte, nous soutenons la proposition de la Banque centrale européenne en vue d’un traitement ultérieur de cette question avec l’ensemble du point 25. |
| 4/13/2005||Bank of Korea|| We are generally in agreement with the recommendations of Advisory Export Group (AEG).
(1) We agree that SPEs should be treated as a separate institutional unit.
(2) SPEs should be treated as resident in their territory of incorporation.
(3) We agree with the AEG that indicative guidelines including the most essential and common factors for the identification of SPEs are needed although an internationally standard definition of SPE is not available in light of the national diversities.
| 4/12/2005||Greece||We agree with the recommendations of the AEG on the issues for which a decision has been taken, at the December 2004 meeting of the group.|
| 4/12/2005||Central Bank of Cote d`Ivoire||Cette proposition appelle la mise à jour du manuel de la balance des paiements (5ème édition) ou tout au moins, des clarifications sur l`identification des entités à vocation spéciale. |
| 4/11/2005||Central Bank of Kuwait||Kuwait agreed that : An SPE incorporated in an economic territory other than any of its owners should be treated as a separate institutional unit and resident in its country of incorporation.|
It is needed for some indicative guidelines on the identification of SPEs across manuals, although an internationally standard definition of SPE is not available in light of the national diversity.
| 4/11/2005||Bank of Tanzania/National Bureau of Statistics||It is necessary to update Balance of Payments manual to include a clarified definition of (SPEs).|
| 4/11/2005||Hong Kong, China||We agree that SPEs should be treated as separate institutional units. Although an international standard definition of SPE is not available, it is desirable that some guidelines on the identification of SPEs can be provided.|
| 4/11/2005||The Netherlands||In relation to holding companies, special purpose entities (SPEs) and trusts, we have some problems with the second recommendation of the AEG as included in the summary conclusions of the December meeting. If international comparabi-lity between national accounts of different countries is to be achieved, an interna-tionally co-ordinated standard definition for SPEs is, in our opinion, essential. We realise that harmonisation of guidelines on the identification of SPEs will be difficult, but due to the increased importance of SPEs in some economies we think that such a standard definition of SPEs is definitely required.|
| 4/11/2005||Iran||We believe that incase holding companies are mainly involved in financial activities, they will be classified under other financial intermediations and their output will be calculated as financial activities. However, if they mainly involve in management activities, they would be classified under business activities and the output thereof will be calculated based upon the received management wage or through adding up expenditures, but if a separate category be specified for holding companies we too, will follow it. In this case, their output might be calculated from the total of expenditures.|
| 4/11/2005||Germany|| m2(c)de25b1; |
| 4/11/2005||Malawi||I fully endorse the recommendations of the Expert Group on National Accounts.|
| 4/11/2005||Central Bank of The Netherlands||Again, we support the decision made by the AEG. We would certainly welcome indicative guidelines on the identification of SPEs in the balance of payments manual and SNA. However, in our opinion these manuals should contain a clear definition as SPEs as well. For some countries - like The Netherlands - transactions by SPEs are very sizable. We feel a strong need for a clear definition that precludes different interpretations between compilers of statistics.|
| 4/11/2005||Philippines ||–In simple cases, SPEs can be treated as residents of the country of incorporation however this term (country of incorporation) should be well defined consistent with the SNA concept of residence. The concept of residence should be discussed deeper in the light of globalization.
There may be a problem in the case of multiple incorporation/registration in several economies. It is also possible that an SPE may be registered in economy but most of its activities are outside of the country or economy of registration. How then do we define SPEs? It may be difficult to have a standard definition at this time but a full description of what it is and what it does would help in the implementation aspect.
| 4/11/2005||Central Bank of the Republic of Turkey||The issue of the residency of SPE’s shoul be discussed comperehensively in the Manual of Balance of Payments.|
| 4/11/2005||Russian Federation||We agree with the recommendations made by the AEG on National Accounts.|
| 4/11/2005||South African Reserve Bank||We accept the recommendations of the AEG.|
| 4/11/2005||South Africa||South Africa agrees with the recommendations.|
| 3/18/2005||Palestinian Central Bureau of Statistics||It is necessary to update the manual of Balance of Payments to include a clarified definition of (SPEs).|