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Executive Report on Strategies in El Salvador
ICON Group International, June 2007, Pages: 390
How to Strategically Evaluate El Salvador
Perhaps the most efficient way of evaluating El Salvador is to consider key dimensions which themselves are composites of multiple factors. Composite portfolio approaches have long been used by strategic planners. The biggest challenge in this approach is to choose the appropriate factors that are the most relevant to international planning. The two measures of greatest relevance are “latent demand” and “market accessibility”. The figure below summarizes the key dimensions and recommendations of such an approach. Using these two composites, one can prioritize all countries of the world. Countries of high latent demand and high relative accessibility (e.g. easier entry for one firm compared to other firms) are given highest priority. The figure below shows two different scenarios. Accessibility is defined as a firm’s ease of entering or supplying from or to a market (the “supply side”), and latent demand is an indicator of the potential in serving from or to the market (the “demand side”).
Framework for Prioritizing Countries
Demand/Market Potential Driven Firm
Relative Accessibility
Accessibility/Supply Averse Firm
Relative Accessibility
In the top figure, the firm is driven by market potential, whereas the bottom figure represents a firm that is driven by costs or by an aversion to difficult markets. This report treats the reader as coming from a “generic firm” approaching the global market - neither a market-driven nor a cost-driven company. Planners must therefore augment this report with their own company-specific factors that might change the priorities.
Latent Demand and Accessibility in El Salvador
This report provides an extremely detailed overview of factors driving latent demand and accessibility in El Salvador. Latent demand is largely driven by economic fundamentals. But, latent demand only represents half of the picture. A country may at first sight appear to be attractive due to a high latent demand, but it is often less attractive when one considers at the macro level how easy it might be to serve that entire potential and/or general business risks.
Chapter 2 deals with macro-accessibility. While accessibility will always vary from one company to another for a given country, the following domains are typically considered when evaluating macro-accessibility in El Salvador:
Openness to Trade in El Salvador
Openness to Direct Investment in El Salvador
Local Marketing and Entry Strategy Alternatives
Local Human Resources
Local Risks
Across these domains, a number of not-so-obvious factors can affect accessibility and risk. These are also covered in Chapter 2, which is presented from the perspective of an American firm, though it is equally applicable to most firms entering El Salvador. This chapter has been authored by local offices of the U.S. Government. I have included a number of edits to clarify the provided information as it relates to the general strategic framework.
In Chapter 3, I summarize the economic potential for El Salvador over the next five years for hundreds of industries, categories, and products. The goal of this chapter is to report my findings on the real economic potential, or latent demand, represented by El Salvador when defined as an area of dominant influence. The data presented are the result of various spatial econometric and time-series forecasting models which, for each category presented, are applied to forecast and allocate latent demand across all countries of the world and major distribution centers or centers of dominant influence within each country. This is accomplished knowing that economic fundamentals (e.g. income) generally vary from one country to another within a given country over time. In this chapter, I report the allocation for each category for El Salvador as an area of dominant influence in Latin America and, potentially, the world.
The report concludes with trade indicators for El Salvador. Often, the amount of trade flowing into and out of a country is a strong indicator of trading partners, trade openness, and related latent demand. Trade indicators are purely statistical in nature. Although international trade is not a direct measure of latent demand, it does provide an indicator of general market conditions with respect to trade flows and trade openness in El Salvador.
As a whole, this report presents a strategic assessment of El Salvador by considering an extremely broad set of factors affecting both latent demand and accessibility, as outlined in the following chapters.
MACRO-ACCESSIBILITY IN EL SALVADOR
Economic Fundamentals and Dynamics
El Salvador is undergoing an economic transition that offers diverse opportunities for export sales and investment. For more than a decade, the economy has been moving from agriculture to manufacturing. Coffee -- long the most important product -- has nearly disappeared as an export income earner. The manufacturing, construction, retail and service sectors have all grown. Clothing assembly “maquila” exports continue to increase despite the slower economic growth in the United States, the main export market. Per capita income has also risen during the last decade. Consumer demand is fueled both by the increase in income and the massive inflow of remittances from Salvadorans living in the United States.
Government Intervention Risks
The government has taken steps to reduce its role in the economy, foremost by privatizations that began in 1990 when the banks were returned to private hands. Later in the 1990s, telecommunications, electric power generation and distribution, and pensions were privatized. The government also created agencies to assist and attract private foreign investment, such as PROESA and the National Investment Office.
Infrastructure Development
Seaports
Acajutla, located 85 kilometers west from San Salvador, is El Salvador’s only operational port. Cutuco, located at the eastern end of El Salvador on the Gulf of Fonseca, is being rebuilt and will be El Salvador’s second port. Salvadoran importers also use Guatemalan and Honduran ports. The Autonomous Executive Port Commission (Comision Ejecutiva Portuaria Autonoma) or CEPA, is the government agency that operates the ports. Vessels transporting solid bulk, general cargo, flour, steel, fertilizers and fuels use Acajutla. The government is in the process of concessionalizing Acajutla’s port services to increase efficiency and private investment. The concession will be granted for 25 years and can be extended for 10 additional years. Prospective concessionaires will have to make a minimum investment of $18 million. The port has 3 piers, 7 landfalls, 4 warehouses and approximately 177 hectares of land.
Airport
The International Airport of El Salvador is in Comalapa about 42 kilometers from San Salvador. The airport, also administered by CEPA, is the hub of Central American air transportation. The passenger terminal includes 17 parking positions, waiting rooms, commercial establishments, baggage claim area and counters, and airlines offices. A smaller airport in Ilopango, on the eastern edge of San Salvador, is currently reserved for military aviation and private use, but is being considered for development as a regional cargo-handling center.
Railways
The National Railways of El Salvador (FENADESAL) is also administered by CEPA.
Telecommunications
Following a successful privatization of the sector, El Salvador has more than 709,000 installed phone lines. El Salvador is also the largest cell phone market in Central America with over 908,000 subscribers in 2002. The major international telephone services are available in El Salvador. There are direct dialing, fax and telex facilities to most countries in the world. The official mail system is inadequate, but there are many private courier services, such as DHL, Federal Express and UPS.
Electricity
Power distribution is entirely privatized. The wholesale generation market remains dominated by CEL, the Salvadoran state-owned electricity company, that supplies more than half of the electricity demand (from hydroelectric and geothermal plants). The remaining capacity is thermal, generally diesel or bunker-fired. There is a limited capacity electric power link to Guatemala that allows for imports of power, but grid incompatibilities currently restrict this trade. A link to the Honduras grid funded by the IDB under the auspices of the new Central American Integration System began operation in May 2002.
Roads/Highways
The Pan-American Highway crosses the country from Guatemala to the eastern Honduran border, connecting the main Salvadoran cities. About 60% of El Salvador’s 3,300 kilometers in roads are paved. About 2,600 kilometers of roads are being repaired and refurbished by the Fondo de Conservacion Vial (FOVIAL), a fund created in 2001 and financed by a gasoline surcharge to maintain the road network.
Political Risks
El Salvador has an excellent relationship with the United States, solidified by years of close cooperation during the civil conflict in the 1980s and by U.S support for reconstruction and reconciliation after the 1992 Peace Accords. Most Salvadorans view the United States in a favorable light, and over 2 million live there.
El Salvador is a multiparty democracy with an independent judiciary. Elections for the single-chamber 84-seat Legislative Assembly are held every three years. The president is elected for a single term every five years.
Marketing Strategies
Creating a Sales Office
The government of El Salvador’s National Investment Office (ONI - Oficina Nacional de Inversiones) operates a “one-stop” window to help foreign companies and individuals complete the requirements needed to obtain a license to establish a business in El Salvador, whether it is a branch, agency, office, or joint venture. Hiring a local legal representative or attorney to work with ONI is recommend as a way to help ensure that all steps are completed.
Once the U.S. investor has provided proof that his company is legally registered in the United States, the Superintendent of Business and Mercantile Corporations (Superintendencia de Empresas y Sociedades Mercantiles) grants authorization for commercial activity and establishes the minimum capital required for the business to begin operations.
Obtain an income and property clearance (this includes an income tax contributor number (numero de identificacion tributaria [NIT]) and a Value Added Tax (Impuesto de Valor Agregado [IVA]) collector number from the General Director of Internal Taxes (Direccion General de Impuestos Internos) and Ministry of Finance (Ministerio de Hacienda).
Request a license at the Commerce Registry at the National Registry Center (Registro de Comercio en el Centro Nacional de Registros [CNR]) in the Commerce and Industry License Registry Department. All companies operating in El Salvador must prepare their accounting records in Spanish. For the issuance of the license, the Registry must approve the Spanish version of the accounting system. The names of the company’s board of directors and administrative personnel must be provided to the Commerce Registry.
Obtain municipal services clearance from the municipality where the company and its facilities will be located and a certification that the firm is properly registered in the National Industrial and Commercial Establishments Directory at the General Director of Statistics and Census (Direccion General de Estadistica y Censos).
Once the Commerce Registry has issued the company’s license, it must be published in a local newspaper. The Salvadoran government must certify the company’s accountants and external auditors. Firms that sell or manufacture pharmaceuticals must obtain a permit from the Superior Council for Public Health (Consejo Superior de Salud Publica). The Council must also approve each of their pharmaceutical products as safe for sale in El Salvador. Companies in the banking and insurance sector that intend to collect deposits, manage investments, or receive payment for premiums or investment services are regulated by the Superintendent of the Financial System (Superintendencia del Sistema Financiero) and must register with this agency.
An environmental permit is required for all activities. This includes activities related to road infrastructure, activities at maritime ports, sewage system, mining, energy transmission, dams, water development, fishing industry, tourist industry, agro industries, urban construction and others listed in the environmental law.
Joint Ventures
Joint ventures involving U.S. and Salvadoran companies must be legally established in a contract signed by both parties. Foreign investments, whether a joint venture, direct investment, partnership, branch or subsidiaries, must be incorporated in El Salvador to operate. Once incorporated and duty registered, the investment enjoys national treatment.
Agents and Distributors
The use of agents and distributors is the most common way to export products and services to foreign countries and a very effective means to market new products. For El Salvador one agent for the country is sufficient as commercial activity is concentrated in the capital San Salvador and the size of the country does not usually justify regional agents. An exclusive territorial contract is recommended only when the business relationship has proven to be stable, professional, and profitable for both parties. For first-time partners or new-to-market companies, an authorized distributor or an alternative to exclusive representation is recommended.
U.S companies should become familiar with Sections “B” and “C” of Chapter III, Title III of the Salvadoran Commercial Code, which regulates the agent and distributor relationship. According to article 392, an agent, representative, or distributor is a natural or juridical person who, on a permanent basis and with or without legal representation and through a contract, is appointed by a principal to establish a representation or distribution agency for a specific product or service in the country. The representation or distribution agency may be exclusive or any other type agreed upon by the parties. The Commercial Code also specifies causes to terminate or modify the contract. These include failure to fulfill the contract, fraud by the agent, serious negligence, and continued decrease in the sale or distribution of the merchandise or services due to the representative agent. Revealing confidential information by the representative agent that prejudices the distribution of the product is also grounds for termination.
If the principal should terminate, modify or not extend the representation, agency or distribution without having met any of the conditions specified in Art. 398 of the Commerce Code, the agent shall be entitled to compensation for the damages. The law describes the compensation allowed.
Hiring Local Counsel
In El Salvador, as in other countries, finding the right partner is a key for success. The local lawyer plays a critical role in providing in-depth analysis of the legal consequences of contracts or agreements with local partners, and other crucial issues. The attorney is also useful to U.S. companies wishing to participate in government tenders. As legal representative, the lawyer can obtain bidding documents and forward them to the company in the United States.
Checking Bona Fides
The success or failure of an operation in a foreign country is often closely tied to quality of the information a company was able to obtain about credit worthiness, bona fides, and business practices of the local partner. The embassy strongly recommends checking the bona fides carefully as soon as a business relationship begins to develop. Some private sector credit-reporting services, including the well-known Dun & Bradstreet, provide credit reports on Salvadoran firms.
Distribution Channel Options
Large distributors usually import most products, and large department stores import directly from manufacturers or exporters. The large distributors have well-established networks of buyers, but handle such a wide range of products that they often cannot dedicate the time and resources necessary to promote new or lesser-known products. Many well-known U.S. products are imported via U.S. distributors in El Salvador and not directly from the producer. As a result, many U.S. products gain name recognition before a formal supplier/distributor relationship is set up. Small retailers often travel to the U.S. to purchase and carry back products themselves. This is especially true for used vehicles and auto parts, clothing, jewelry, cosmetics, computers and certain household goods.
Franchising Activities
While U.S. franchises have been present in El Salvador for at least 30 years, they began to increase rapidly during the last eight years and this trend has accelerated. U.S. fast-food franchises (such as pizza, sub sandwiches, and hamburgers) have been the most successful. Despite the increasing number of used vehicles imported in recent years, automotive service franchises have not yet had much success in the market. Office supply franchises have also not been as successfully as market conditions would call for. U.S franchises operating in El Salvador include hotel and car rental; auditing/accountancy, credit reports, mobile advertising and media marketing, print shop/one hour photo labs, beauty/hair salons, fitness centers, computer learning, child care/learning centers, video rental, and dry cleaning. A trademark protection law passed in 2002 improved protections of trademarks and distinctive signs to international standards. To get full protection, the trademarks must be registered at the Intellectual Property Registry at the National Registry Center. A longstanding dispute between a prominent U.S. franchise and its former franchisee suggests that enforcement of franchise contracts in the courts can be difficult, and we urge franchisers to develop their business cautiously and based on careful analysis of the business bona fides of their potential franchisees.
Direct Marketing Options
Privatization of telecommunications has greatly improved the possibilities for direct marketing by allowing telemarketing services and created new target audiences on cable television. The number of cellular phone and Internet users has dramatically increased. Reliable telecommunication services have allowed more use of fax communication features and E-mail. As a result, direct marketing is easier than before. Although the GOES is making efforts to upgrade its public mail system, the business sector normally uses local private delivery companies. Door-to-door sales by U.S. cosmetics and household products firms, under-the-door-promotional flyers and direct-from-television sales are increasing. Electronic commerce is still in an early stage. The American Chamber of Commerce helped draft a bill to promote and regulate e-commerce in El Salvador.
Selling Strategies
New consumer products are often introduced at a reception in an upscale hotel, together with a newspaper and billboard ad campaign. As competition increases, creative sales promotions such as contests, drawings, raffles, etc., become more relevant. Samples of products are often handed out at supermarkets and department stores. Participation in local exhibits and sponsorship of local events and conferences is a common local practice for brand positioning. Shared budget for promotional campaigns and advertising is highly appreciated by local importer/distributor, and simple things such as the availability of brochures and other promotional materials in Spanish are very helpful for marketing products. U.S. companies interested in finding representatives or distributors to sell should look for ways of adding value to the relationship, such as supporting local marketing efforts in order to increase potential sales. Each sector has its peculiarities and techniques; therefore the Economic Commercial Section encourages U.S. companies to approach the Embassy for specific information.
Pricing Issues
In general, there are no controls on prices in El Salvador. The exceptions are liquefied propane gas, public transport rates, and energy, which the government regulates. The government regulatory agency, the General Superintendent of Electricity and Telecommunications (SIGET), regulates electricity and telecommunications. Government ministries directly subsidize water services and establish the distribution service tariff. The Ministry of Economy closely monitors credit card interest rates and gasoline retail prices through its consumer protection office.
For imported products, price structure includes import duty and the 13-percent value-added tax (VAT) that must be added to the purchase price of all products, including basic food products and medicines. Import tariffs for capital goods are zero percent, raw materials range from zero to 5%, intermediate goods range from 5 to 10%, and final goods are charged a maximum of 15%. Textiles, agricultural products, vehicles, and a few other non-essential products are charged higher tariffs that range from 15 to 30%. These new tariffs apply to products coming from outside the Central American Common Market. A comparative chart of Central American import duties can be found at http://ns.sieca.org.gt/ArancelVigente/Arancel.asp, the Central American Economic Integration System Web site.
Licensing Options
Licensing is included in the Law for Trademarks and Other Distinctive Signs, approved in 2002, which raises protections for trademarks and distinctive signs to internationally accepted standards and obliges national and foreign firms to register in the Commerce Registry and the Intellectual Property Registry. To have the exclusive right of exploitation of commercial names, trademark, any expression and/or advertising sign, including patents and industrial designs, an attorney or legal representative must register the trademark at:
Registro de Propiadad Intelectual
Centro Nacional de Registros
1a. Calle Poniente y 43 Ave. Norte No. 2310
San Salvador, El Salvador
Tel: (503) 260-8000
Fax: (503) 260-7916
Advertising and Trade Promotion
Advertising in El Salvador is mainly through TV, radio, newspapers, billboards and leaflets. Depending on the target market, nature of product, purpose of the message or marketing plan, advertising agencies will recommend the most appropriate media mix.
In terms of mass communication, the country has four VHF commercial television stations; channel 2, 4, 6 and 12, three of which are a conglomerate that reaches approximately 80% of the viewers. Five newspapers circulate in the country with an estimated daily circulation of 281,000. Four of these have Internet versions. Two of the newspapers are the leading dailies with nationwide coverage and about 75% of the total circulation. The main radio stations are located in the city of San Salvador. There are approximately 200 FM radio stations in the country but only 20% broadcast nationwide. Statistics indicate that 70% of FM stations are music, 30% are news programs, comments, sports and/or educational. The American Chamber of Commerce, the Chamber of Commerce and Industry and the Salvadoran Association of Industry, as well as other trade organizations, circulate monthly and bi-monthly journals that accept advertising.
Newspapers
La Prensa Grafica
Tel.: (503) 241-2364
Fax: (503) 241-2000
http://www.laprensa.com.sv
Estimated circulation: over 90,000 nationally
El Diario de Hoy
Tel.: (503) 271-0100
Fax: (503) 271-2040
http://www.elsalvador.com
Estimated circulation: over 90,000 nationally
El Mundo
Tel.: (503) 225-3300
Fax: (503) 225-3178
http://www.elmundo.com.sv
Estimated circulation: 30,000 mainly in the capital
Mas
Tel.: (503) 281-1477
Fax: (503) 222-2046.
Estimated circulation: 30,000 mainly in the capital
Co-Latino
Tel.: (503) 271-1303
Fax: (503) 271-0971
www.diariocolatino.com.sv
Estimated circulation: 14,000
Supplying Customer Service
With over 2 million Salvadorans resident in the United States, Salvadorans are familiar with U.S. products and would like to receive U.S. customer service. Sellers can get an edge by offering good service and customer support. Consumers and/or end user purchasing decisions respond differently depending on the product or sector, but in general they are price oriented, tied to credit conditions and to after-sale service.
Public Sector Marketing
In April 2000, the GOES enacted a modern and transparent government procurement and contracting law, which increased the efficiency and transparency in public sector purchases and contracting procedures and helped to eliminate corruption.
For small government purchases, sellers should contact the procurement office in each ministry or autonomous institution, consult postings on the Web pages of each institution, or for general information go to http://www.servicios.gob.sv. Generally, sellers need to speak Spanish to be successful. For purchases worth more than US$10,000-20,000 dollars (depending on the ministry or agency), the government publishes a tender in the major newspapers and/or sends written notices to various embassies. Salvadoran law calls for civil engineering and construction projects that are financed by the Government of El Salvador’s own funds to give preference to Salvadoran companies. However, since most large projects receive aid or loans from international financial institutions, and therefore are open to U.S. companies, this law is not a major trade barrier. Government tenders received by the U.S. Embassy are placed on the Department of Commerce’s National Trade Data Bank or on-line Electronic Bulletin Board as “Foreign Government Tenders” or in the “Business Development” publication of the Inter-American Development Bank. While a WTO member, El Salvador has not signed the government procurement agreement.
Import and Export Regulation Risks
Adherence to Free Trade Agreements
The United States-Central America Free Trade Agreement (CAFTA) negotiations, launched in January 2003.
Central America-Chile free trade agreement, entered into force in June 2002
Central America-Panama free trade agreement, entered into force in October 2002
Central America-Dominican Republic free trade agreement, entered into force in October 2001
Northern Triangle (El Salvador, Guatemala, Honduras)-Mexico free trade agreement, entered into force in March 2001
General Treaty for Central American Integration, signed December 13, 1960, created Central American Common Market (CACM). After nearly two decades in abeyance, CACM was revived in the early 1990s. The five countries have agreed on maximum tariffs and now seek to harmonize tariff rates and to establish a customs union in 2004.
The Central American countries and Canada are negotiating a free trade agreement.
El Salvador participates in the Free Trade Area of the Americas (FTAA) negotiating process and is a beneficiary of the tariff preferences of the Caribbean Basin Initiative and the Generalized System of Preferences. El Salvador belongs to the World Trade Organization (WTO).
Trade Barrier Risks
El Salvador uses the CACM’s Central American Import Tariff, which contains the nomenclature for the official classification of goods for the Central American Tariff System (SAC), the import duty rates, and the rules for application. The SAC is based on the Harmonized Commodity Description and Coding System (HS). Currently, all Salvadoran imports originating within the CACM enjoy a zero tariff -- except roasted and unroasted coffee, sugar cane, ethyl alcohol and distilled alcoholic beverages, and petroleum products.
Tariffs for goods from outside the CACM are the following:
Capital goods, zero percent;
Raw materials, zero to 5%;
Intermediate goods 5 to 10%;
Final goods, 15%;
Clothing, dairy and meat products, vehicles, and a few other non-essential products such as alcoholic beverages are charged higher tariffs that range from 15 to 40%.
El Salvador’s average tariff rate is 7.4%.
El Salvador maintains import tariff quotas for certain agricultural products and some products can only be imported when the domestic supply is insufficient.
Restrictions on Imports
Weapons
The import of certain high-caliber firearms is prohibited. Arms for personal defense or hunting may be imported, but are strictly controlled by the police and Ministry of Defense based on a special law that also controls sales to the public and to private security companies.
Drugs
Cocaine, opiates and barbiturates may be imported solely for medical use, with the permission of the Superior Council for Public Health (Consejo Superior de Salud Publica). The Council controls the sale of these substances to the public. Tranquilizers, sedatives, anti-depressants and certain antibiotics were recently added to the list of prescription medicines
Others
Other items that are either prohibited or restricted:
Books, booklets, emblems, posters and any other articles of a subversive character or doctrines contrary to the established political, economic and social order.
Figures, statues, books, booklets, almanacs, magazines, engraved or lithographed articles, newspapers, lithographs, stamps, photographs, and cards of an obscene nature or any other obscene articles (including common magazines such as Playboy).
Movies contrary to ethics and good behavior
Abortives
Gambling machines. Not prohibited, but subject to authorization by the Ministry of Finance and local municipalities.
Roulette wheels, gambling tables, and any other item or article used for gambling. Not prohibited, but subject to authorization by the Ministry of Finance and local municipalities.
Opium with less than 9% morphine, scraps and opium ash, and any material used for smoking those products.
Non-stamped paper for cigarettes, white or colored in rolls, spools, booklets or small tubes.
Machines and tools for making coins
Counterfeited coins and bills
Plain silver coins of less than 0.90 purity
Tokens of any metal or alloy that may be used as substitutes for legal coins
Coffee trees and coffee seeds for planting
Light passenger or cargo motor vehicles in use for more than 8 years and heavy passengers and cargo motor vehicles in use for more than 15 years.
Anyone considering the import of these items should consult with the appropriate government regulatory agency for exemptions or special permits.
Some goods are subject to a “limited import prohibition”; only the State can import them. They include military airplanes and ships, gas masks for military use; potassium nitrate; stamped paper for making cigarettes; fiscal, municipal and post stamps; and nickel coins for legal circulation.
U.S.-Imposed Controls on Salvadoran Exports
El Salvador’s iguana-export industry is regulated by the provisions of the Convention on International Trade in Endangered Species (CITES). In 2000, El Salvador’s shrimp industry was certified as complying with U.S. government standards for use of turtle excluder devices (TEDS). Salvadoran tuna exports to the United States have been embargoed since 1997 because of lack of certification for fishing practices that protect dolphins. In 1995, a bilateral agreement was reached with the U.S. to restrict the shipment of certain categories of archaeological materials into the United States.
Import Tariffs and License Requirements
Imports are also subject to internal taxes. These include the 13% value-added tax (VAT) and various selective taxes on products such as alcoholic beverages, carbonated beverages, and cigarettes.
In most cases Customs does not require import licenses. Imported vegetables or animals do require a license from the Ministry of Agriculture to certify that the goods meet local health and sanitary regulations. Firearms and ammunition require a license from the Ministry of Defense. Documents needed for processing imported goods through Customs include:
Import license (if animal, vegetable or firearms)
Commercial invoice
Bill of lading, airway bill or carta de poder.
When imports come from the Central American Common Market region the only document required is the Customs Form (Formulario Aduanero).
Customs Regulations
Customs Assessments
The amount set forth in the commercial invoice is used for tax purposes. If there is doubt about the accuracy
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