Improving Information to the Croatian Business Community … · 2017-01-12 · Organising study...

Improving Information to the Croatian Business Community: BIZimpact II

Service Contract No. IPA2007/HR/16IPO/001-021401 EIA Database Report

EIA database report

1

The European Union’s “Regional Competitiveness Operational Programme” for Croatia

IPA2007/HR/16IPO/001-021401

Improving Information to the Croatian Business Community — BIZimpact II

Activity 1.3: Economic Impact Assessment Information Base

Hrvoje Renka

This project is funded by the

European Union

Ministry of Entrepreneurship and

Crafts

Improving Information to the Croatian Business

Community

Pohl Consulting and Associates GmbH

POHL CONSULTING & ASSOCIATES



EIA database report

2

0.I. PROJECT SYNOPSIS

Contract Reference: Country of Assignment: Project Duration: Contracting Authority:

EuropeAid/131132/D/SER/HR Republic of Croatia 24 months Central Finance and Contracting Agency,

Ms Dunja Bonacci Skenderović

Project Title:

Improving information to the Croatian Business Community — BIZimpact II

Reporting Period:

Second period

Report Submitted on:

18 December 2013

Contractor:

Pohl Consulting and Associates GmbH Pinto Consulting GmbH Altair Asesores West Midlands Enterprise

Project Director: Andreas von Brühl-Pohl Team Leader: Dr Ricardo Pinto Project Officer: Marko Šilinger

Project Partner and Main Beneficiary:

Ministry of Entrepreneurship and Crafts (MINPO)

Project Manager: Ms Veronika Tolj Project Coordinator: Ms Jasminka Keser

Commission Representation in Croatia: Project Manager:

N/A

Brief Context of the Assignment:

The Overall Objective of the project is the "Improvement of the business environment thus enhancing the competitiveness in the country" (ToR, p.8). The Project Purpose is threefold:

Further develop the capacity of policy makers and business organisations to identify, analyse and communicate future impact of key regulatory areas for business in Croatia;

Improve the awareness of the business community regarding these key areas; Leverage the development of a stronger culture of entrepreneurship specifically focused on regional

development. The following Planned Results are anticipated:

Economic Impact Assessment (EIA) [for SMEs] developed and implemented; Consultation process/Public-private Dialogue with business community and awareness of the

business community in key legislative fields improved; Dissemination of Information and Awareness-raising upgraded; Development of partners/regional capacities for information campaigns conducted.

Specific Objectives of the Assignment:

Component 1: Economic impact assessment for SMEs Activities include:

Developing a methodology for Economic Impact Assessment (EIA) for SMEs (measuring the economic impact of new laws and regulations), including an “SME test” in line with best EU practice;

Publishing a Manual and providing training on EIA for SMEs procedures; Developing an EIA for SMEs information base; Developing a Virtual Centre of Excellence on EIA for SMEs;



EIA database report

3

0.II. DIRECTORY OF KEY PROJECT STAKEHOLDERS

Ministry of Entrepreneurship and Crafts Ulica grada Vukovara 78, 10000 Zagreb Tel: +385 1 610 61 11 [email protected]

Croatian Agency for SMEs and Investments Prilaz Gjure Deželića 7, 10000 Zagreb Tel: +385 1 488 10 03 [email protected]

Croatian Association of Cooperatives Amruševa 8/1.kat, 10000 Zagreb Tel: +385 1 487 00 53 [email protected]

Croatian Chamber of Economy Rooseveltov trg 2, 10000 Zagreb Tel: +385 1 456 15 55 [email protected]

Croatian Chamber of Trades and Crafts Ilica 49/II, 10000 Zagreb Tel: +385 1 480 66 66 [email protected]

Croatian Employers’ Association Pavla Hatza 12, 10000 Zagreb Tel: +385 1 489 75 55 [email protected]

Organising study tours; Organising awareness-raising campaigns and events on EIA for SMEs.

Component 2: Development of consultation process/Public Private Dialogue with business community within the context of EIA for SMEs Activities include:

Evaluating current Public-Private Dialogue mechanisms and recommending improvements relevant to the EIA for SMEs consultation process;

Developing the consultation process and an accompanying manual; Developing a Croatian Business Test Panel; Developing and implementing tools for e-consultation.

Component 3: Dissemination of Information and Awareness-raising Activities include:

Updating and republishing the existing seven Mini Guides for SMEs produced during the first stage of the project;

Developing and publishing a new series of Mini Guides on new legislative areas, based on research of the needs of small businesses;

Providing training to beneficiaries and other partners on the legislative areas covered by the new Mini Guides;

Developing and publishing a newsletter and e-newsletter containing essential information for small businesses.

Component 4: Development of partners/regional capacities for information campaigns Activities include:

Assessing beneficiaries’ communications activities and recommending improvements; Developing Communication Strategies and Action Plans for each beneficiary plus an accompanying

manual relating to the awareness-raising campaigns and activities of the project; Organising national visibility events; Organising regional information campaigns and visibility events; Undertaking a survey of small businesses regarding their key information needs and priorities.

The opinions expressed in this Report are those of the authors and do not necessarily reflect the opinions of the

European Union or any other organisation mentioned. As a result, these will be verified before implementation of



EIA database report

4

Contents 0.I. PROJECT SYNOPSIS ................................................................................................................. 2

0.II. DIRECTORY OF KEY PROJECT STAKEHOLDERS .......................................................................... 3

ACRONYMS .................................................................................................................................. 6

1. EXECUTIVE SUMMARY .......................................................................................................... 7

2. INTRODUCTION................................................................................................................... 10

2.1 Context: RIA, EIA and EIA for SMEs ............................................................................... 10

3. POTENTIAL SOURCE OF EIA FOR SMES DATA ........................................................................ 14

3.1 Introduction and Context ............................................................................................. 14

3.1.1 Legal Framework ........................................................................................................ 14

3.1.2 RIA and EIA ................................................................................................................. 16

3.1.3 EIA Variables .............................................................................................................. 17

3.2 Sources of Information relevant for EIA for SMEs .......................................................... 18

3.2.1 Ministry of Entrepreneurship and Crafts (MINPO) ..................................................... 19

3.2.1.1 Register of Measures and Incentives for SMEs ....................................................... 19

3.2.1.2 Register of Crafts .................................................................................................. 20

3.2.2 Croatian Agency for Small Enterprise and Investment (HAMAG INVEST) .................... 22

3.2.3 Croatian Chamber of Economy (HGK) ....................................................................... 23

3.2.4 Croatian Chamber of Trades and Crafts (HOK) ........................................................... 23

3.2.5 Croatian Employers’ Association (HUP) ..................................................................... 24

3.2.6 Croatian Association of Cooperatives (HSZ) ............................................................... 25

3.2.7 Central Bureau of Statistics (DZS) ............................................................................. 25

3.2.8 Financial Agency (FINA) ............................................................................................ 26

3.2.9 Tax Administration ................................................................................................... 27

3.2.10 Agency for support to IT systems and technologies (APIS IT Ltd) ............................ 27

3.2.11 The Central Register of Affiliates (REGOS) ............................................................. 28

3.2.12 Register of Pension Payments (HZMO) .................................................................. 29

3.2.13 SMEs and Entrepreneurship Policy Centre (CEPOR) ............................................... 30

3.2.14 Economic Institute, Zagreb (EIZ) ............................................................................ 30

3.2.15 IPA Project Improvement of Administrative Efficiency on National Level (IAENL) ... 30

3.3 Summary of Available Data .......................................................................................... 31

4. CONCLUSIONS AND RECOMENDATIONS .............................................................................. 34

4.1 Conclusions .................................................................................................................. 34



EIA database report

5

4.2 Recommendations ....................................................................................................... 36

LIST OF ANNEXES

ANNEX I: List of the meetings for identification of data sources for EIA information base

ANNEX II: Paper on strengths and weaknesses of Croatian data sources produced by the

Improvement of Administrative Efficiency Project

ANNEX III: Type of data collected in the Support Register of Measures and Incentives for SMEs

(MINPO)

ANNEX IV: Type of data collected in the Crafts Register (MINPO)

ANNEX V: Two most often requested HAMAG INVESTs supports to SMEs – Request for Guarantee (for

credit/loan) and Letter of Intention

ANNEX VI: Type of data collected by HGK

ANNEX VII: Type of data collected by HOK

ANNEX VIII: Type of data collected by HSZ

ANNEX IX – Type of data collected by FINA

ANNEX X – Type of data collected by Tax Administration

ANNEX XI – Type of data collected by REGOS



EIA database report

6

ACRONYMS

Acronym/term Meaning

AFR Annual Financial Report

BIZimpact Improving Information to the Croatian Business Community

BSO Business Support Organisation

CARnet Croatian Academic and Research Network

DZS Central Bureau of Statistics

EIA Economic Impact Assessment

EU European Union

FINA Financial Agency

GEM Global Entrepreneurship Monitor

GLO Government’s Legislation Office

HAMAG INVEST Croatian Agency for SMEs and Investments

HGK Croatian Chamber of Economy

HOK Croatian Chamber of Trades and Crafts

HSZ Croatian Association of Cooperatives

HZMO Register of Pension Payments

HUP Croatian Employers’ Association

HZMO Croatian Pension Insurance Fund

IA Impact Assessment

IAENL Improvement of Administrative Efficiency on the National Level

IPA Instrument for Pre-Accession Assistance

MINGORP Former Ministry of Economy, Labour and Entrepreneurship

MINPO Ministry of Entrepreneurship and Crafts

NACE Nomenclature statistique des activités économiques dans la Communauté

européenne

OG Official Gazette

REGOS Central Register of Affiliates

RIA Regulatory Impact Assessment

SME Small and Medium Entrepreneurship

ToR Terms of References

VAT Value Added Tax

VCoE Virtual Centre of Excellence



EIA database report

7

1. EXECUTIVE SUMMARY

This report covers Component I, Activity 1.3 of the project, namely “Survey and Economic Impact

Assessment Information Base”. It aims to identify the potential variables that are of relevance to

economic impact assessment (EIA) for the small and medium-sized enterprises (SMEs) and to make

recommendations for the development of an EIA for SMEs information base, based on the existing

information sources, variables, processes and institutions.

Discussions on the available information suitable for the EIA for SMEs and analysis of these

information lead to three main conclusions:

The quantity of SME information is generally satisfactory, but only up to a certain point. The

coverage of the crafts sector, which represents a little over 50% of all businesses, is not

satisfactory, as most crafts do not submit detailed financial reports. Comprehensive information is

available only for number of crafts, number of employees and total income of crafts;

Numerous institutions collect and process SME information resulting in fragmentation;

Information on SMEs is currently not integrated into a single information base of SME data.

This leads to the conclusion that it is necessity to establish a single data source that integrates all the

relevant SME information, as required by the recent and amendments to the Small Business

Development Promotion Act (OG 29/02, 63/07, 53/12 and 56/13). However, it should be noted that

this is not the specific focus of the BIZimpact II project. The aim of Activity 1.3 is merely to identify

the pool of information which is currently available and which has the potential to be uses in relation

to future EIA for SME analyses.

The process of developing an information base on EIA for SME focuses on the following aspects:

Identification of the key sources of information relevant for EIA for SMEs both within the

BIZimpact project’s beneficiary organisations, as well as other relevant institutions;

Meetings with project beneficiaries and institutions that are potential sources of information;

Identification of the key variables relevant for EIA for SMEs;

Preparation of recommendations for the establishment of the EIA for SME information base; and

Preparation of an EIA for SME information base in line with the recommendations, including

integration into the planned Virtual Centre of Excellence on EIA for SMEs in the future.

This included the identification of the key institutions that have relevant information for EIA for SMEs

followed by meetings and discussion with such institutions, leading to the identification of main

variables that could be included in the EIA for SMEs information base. Such institutions include:

MINPO (Support Register of Measures and Incentives for SMEs and Crafts Register);

Croatian Agency for Small Enterprise and Investment (HAMAG INVEST);

Croatian Chamber of Economy (HGK);

Croatian Chamber of Trades and Crafts (HOK);

Croatian Employers’ Association (HUP);

Croatian Association of Cooperatives (HSZ);

Central Bureau of Statistics (DZS);

Financial Agency (FINA);



EIA database report

8

Tax Administration;

Agency for support to IT systems and technologies (APIS IT Ltd);

The Central Register of Affiliates (REGOS);

Register of Pension Payments (HZMO);

SMEs and Entrepreneurship Policy Centre (CEPOR);

Economic Institute, Zagreb (EIZ);

IPA Project Improvement of Administrative Efficiency on National Level (IAENL).

However, such work did not happen in a policy vacuum. A key part of the BIZimpact II project is the

development of a Manual on EIA for SMEs. Therefore, in identifying the possible variables for EIA for

SMEs, the relevant recommendations of the EIA for SMEs Manual were followed. The EIA for SMEs

Manual lists the main questions in the implementation of the EIA for SMEs, namely:

Which sectors of the economy will be affected?

Which industries will be affected?

What are the employment characteristics of the affected sectors?

What is the recent/current economic performance of the affected sector (output, employment,

investment, trade, etc.)?

The EIA for SMEs Manual also stresses that EIA should assess the likely impact of the proposed

regulation on the economic performance of the affected sectors. The key indicators to be considered

include:

What is the likely impact on employment?

What is the likely impact on output?

What is the likely impact on productivity?

What is the likely impact on investment?

Thus, in line with the Manual for EIA for SMEs (2013), the following variables are of importance in

relation to EIA for SMEs:

Number of Business Subjects;

Number of Employees;

Costs of Doing Business;

Turnover;

Income (Gross/Net);

Profitability;

Productivity (input vs. output values);

Investments (total, R&D, innovation, etc.);

Taxation;

National Insurance Contributions.

Furthermore, it is important to subdivide the above variables as follows:

Legal type;

Size;

NACE code;

Sectorial division;



EIA database report

9

Geographical division (up to county level).

In the best-case scenario, there should also be the possibility to combine different subdivisions (e.g.

number of micro companies by NACE code).

Based on the meetings and analysis of the possible variables for the information base for EIA for

SMEs, the main conclusions and recommendations are highlighted below.

Sources of information

The ideal source of information for the EIA for SMEs information base would be an integrated,

methodologically consistent source applying to the entire SME sector but unfortunately, this is

not possible in Croatia. The legal business subjects and cooperatives are covered through the

Annual Financial Returns submitted to FINA but that does not apply to the vast majority of crafts

(approximately 5% of all crafts submits their financial report to FINA). Data on crafts are

dispersed between different institutions and registers;

The original source of information on crafts, MINPOs Crafts Register, has IT limitations which

constrain the extraction of all the information that exists in the register. In addition, the Crafts

Register would need to be merged with other sources of information, such as Tax Office, REGOS

and HZMO data. Due to these issues, HOKs “Book of Crafts” is the most comprehensive source of

information on crafts. Consequently, the EIA for SMEs information base will be develop using

FINA and Book of Crafts data.

Variables

The information base on EIA for SMEs should include the following:

o Number of Business Subjects;

o Number of Employees;

o Costs of Doing Business;

o Turnover;

o Income (Gross/Net);

o Profitability;

o Productivity (input vs. output);

o Investments (total, R&D, innovation etc.).

Not only are the variables listed above limited, they are not necessarily always available for the

whole sector of SMEs, co-operatives and crafts. Only basic information is available on crafts such

as their number, employees and turnover (these can be separated according to county level and

NACE code).



EIA database report

10

2. INTRODUCTION

The Improving Information to the Croatian Business Community (BIZimpact II) project lasts for two

years from March 2013 to March 2015 and is a follow-up to the first BIZimpact Project implemented

in 2007-2009. It forms part of the “Regional Competitiveness Improvement Programme” funded by

the European Union (EU) Instrument for Pre-Accession Assistance (IPA) Programme and the

Government of the Republic of Croatia. The main beneficiary of the project is the Ministry of

Entrepreneurship and Crafts (MINPO). Other beneficiaries are the Croatian Agency for SMEs and

Investment (HAMAG INVEST), the Croatian Chamber of Economy (HGK), the Croatian Chamber of

Trades and Crafts (HOK), the Croatian Employers’ Association (HUP) and the Croatian Association of

Co-operatives (HSZ).

The overall Project objective is to improve the business environment, thus enhancing

competitiveness in the country. The specific purposes of the BIZimpact II project are to:

Develop further the capacity of policy-makers and business organisations to identify, analyse and

communicate future impact of key regulatory areas for business in Croatia;

Improve awareness of the business community regarding key regulatory areas; and

Leverage development of a stronger culture of entrepreneurship specifically focused on regional

development.

This report covers Component I, Activity 1.3 of the project, namely “Survey and Economic Impact

Assessment Information Base”. It’s focus is to identify the potential variables that are of relevance to

the economic impact assessment (EIA) for the small and medium-sized enterprises (SME) and make

recommendations for the development of an EIA for SMEs information base, based on the existing

information sources, variables and institutions.

2.1 Context: RIA, EIA and EIA for SMEs

Since the completion of the first BIZimpact project (2007-2009), a Regulatory Impact Assessment

(RIA) System has been established in Croatia, the key features of which are illustrated below:

The Government Office for Legislation (GLO) took responsibility for the overall RIA system; The Law on Impact Assessment (Official Gazette (OG) 90/2011) which entered into force in 2012; The Regulation on Implementation of RIA (OG 66/12) came into force; The RIA Strategy and Action Plan were developed and approved (2012); Three RIA Guidelines were prepared for i) GLO ii) Ministries and iii) Stakeholders (2012); MINPO was established with specific responsibility for SMEs, including EIA for SMEs.

The RIA Law (2011) and Regulation (2012) set the framework for the RIA system. Its key features

include the following:

RIA is mandatory for the Government’s annual legislative plan; There are four types of IA, namely fiscal, economic, environmental and social welfare; GLO co-ordinates the implementation of the RIA Strategy, Guidelines and Action Plan; GLO is responsible for capacity building of civil servants in relation to RIA; GLO oversees the individual Preliminary Impact Assessments; Competent Authorities are required to appoint a Co-ordinator;



EIA database report

11

Competent Authorities may (but do not have to) establish a RIA Unit; The Co-ordinator (and any other RIA officers) will co-ordinate IA with initiators of legislation; IAs include an analysis of the current situation, examination of policy options (at least two

regulatory and two non-regulatory options), positive and negative impacts and fiscal impact; Consultation on draft is required (at least 30 days, more if complexity justifies it), including

posting draft regulations / RIA statements on Competent Authorities’ web sites; Public hearings can last between 15 and 30 days; Competent authorities must provide opinions within 15 working days of receipt; Impact statements are final once the Competent Authority and GLO approve them.

According to the RIA Regulation (Paragraph 3, Article 4, 2012), all IAs must include:

“Expected impacts on the economy in total are assessed in relation to economic objectives,

which are to be accomplished by Regulation, particularly related to the following criteria:

Competitiveness of the economy and inflow of the investments; Economic growth; Environmental sustainability; The achievement of goals of social and regional development; Specific regions and sectors; Macroeconomic environment; Market competition; and Other expected impacts on the economy if they are evaluated as significant in line with

the assessment of the expert bearer.”

However, although the expectations of the IAs are set out in general terms, the Law, Regulation and

Guidelines are not specific on the actual requirements for EIA per se (or indeed any of the other

prescribed forms of impact assessment). At the time of the adoption of the RIA Law, it was assumed

that the former Ministry of Economy, Labour and Entrepreneurship (MINGORP) would take

responsibility for defining the nature of the EIA. However, in the meantime, this former ministry has

been divided into three ministries, all of which have responsibility for aspects of EIA, namely:

Ministry of Economy (MINGO): focus on EIA for the economy as a whole, with a focus on large and/or state owned enterprises;

Ministry of Labour and Pension System (MRMS): focus on EIA for the labour market; Ministry of Entrepreneurship and Crafts (MINPO): focus on EIA for SMEs, Crafts and Cooperatives.

Therefore, MINPO’s methodology for EIA must integrate and prioritise the explicit assessment of

impacts on SMEs (i.e. it must be understood as the Methodology on EIA for SMEs, which includes

Crafts and Cooperatives). Separate Activities of the BIZimpact II project will develop the EIA for SMEs

methodology, manual, etc. which will determine the exact nature of the EIA for SMEs.

For MINPO, as well as other Ministries and stakeholders included in the RIA process, this implies the

necessity to develop an information base that could be used for this purpose. However, despite the

existence of the Central Bureau of Statistics (DZS) as the central Croatian statistical institution and

efforts on the part of the EU co-financed project “Improvement of Administrative Efficiency on the

National Level” (IAENL) on improvement of the quality and quantity of available information, a

comprehensive information base on SMEs does not exist. However, based on the recently approved

changes and amendments on the Small Business Development Promotion Act (OG 29/02, 63/07,



EIA database report

12

53/12 and 56/13), MINPO is required to prepare a central information system of small business, as

illustrated in the following extract:

Article 6

(2) The Ministry in charge for Entrepreneurship and Crafts must establish a central information system of SMEs

as a full-scale and comprehensive system for implementation and monitoring of the SME development

measures and instruments and evaluation of the economic impacts on the national and regional level.

Article 7

(3) All bearers of the implementation of measures and instruments of SME promotion, for the purpose of this

Law, will be connected to central information system of SMEs.

MINPO has the ambition of creating a central information system of small business, and initiative

that is to be welcomed. However, the BIZimpact II project’s aims clearly represent merely a step in

the long-term process of achieving this vision for SME data.

Discussions and analysis, for example with experts from the Improvement of Administrative

Efficiency on the National Level (IAENL) Project, lead to two main conclusions:

The quantity of SME information is generally satisfactory, but only up to a certain point. The

coverage of the crafts sector, which represents a little over 50% of all businesses in Croatia, is not

adequate because they do not submit detailed financial reports and comprehensive information is

available only for number of crafts, number of employees and total income of crafts;

Numerous different institutions collect and process information but these are not integrated into a single information base of SME data.

As a part of its activities, IAENL Project had assembled Working Group for Statistical Analysis. During implementation of the project, the Working Group for Statistical Analysis identified the main gaps, inconsistencies and shortcomings in data sources in the area of SMEs. The result was a document summarising the problems of data collection and availability (see Annex I). The conclusion that arose is the necessity to establish a single information base which integrates all the relevant SME information, as accepted in the changes and amendments on the Small Business Development Promotion Act (OG 29/02, 63/07, 53/12 and 56/13). However, it should be noted that this is not a requirement under the BIZimpact II project. Rather the focus of Activity 1.3 is to identify the pool of information which is currently available and which can be potentially used in relation to future EIA for SME analyses.

It should be noted that the EIA for SMEs information base is to be connected with Activity 1.5: Virtual

Centre of Excellence (VCoE) on EIAs for SMEs, which involves the development of the VCoE as a

“location” of various kinds of information connected with EIA for SMEs. The proposed EIA for SMEs

information base would be linked to the VCoE, allowing the information to be available to users of

the application. There is a possibility of connecting the EIA for SMEs information base with other

sources of information, such as Financial Agency (FINA), however, this is not a project output and

issues such as possible technical limitations and availability of finance would influence

implementation, as well as plans for the realisation of the central information system of SMEs.



EIA database report

13

The process of developing the information base on EIA for SME focuses on the following aspects:

Identification of the key sources of information relevant for EIA for SMEs inside BIZimpact’s beneficiaries’ and additional institutions with information sources relevant for EIA for SMEs;

Meetings with representatives of the project beneficiaries and institutions/organisations that are identified as a potential source of information (a form of qualitative survey);

Recommendations for the establishment of the EIA for SME information base; and Preparation of the EIA for SME information base in line with the results of the report, including

integration into the Virtual Centre of Excellence on EIA for SMEs.

The rest of the report covers the following issues:

1. Definition of most important variables for EIA; 2. Identification of main sources of information on SMEs in Croatia relevant for EIA; 3. Recommendations for data to be incorporated into the EIA Information Base; 4. Preparation of the EIA Information Base in line with the recommendations.



EIA database report

14

3. POTENTIAL SOURCE OF EIA FOR SMES DATA

3.1 Introduction and Context

This report focuses on the implementation of Activity 1.3: Survey and Economic Impact Assessment

Information Base of the BIZimpact II project. In essence, this activity involves three main steps: i) a

survey of potential data sources (i.e. survey in the sense of identification of the relevant information

based on meetings and discussions with the relevant institutions), ii) recommendations as to what

information the EIA for SMEs information base should include, and iii) preparation of the EIA for

SMEs information base.

In order to understand SME information, coverage and availability, it is necessary to understand the

various types of business subjects in Croatia, in other words the legal definitions of the different

types of business subject. Furthermore, it is only when we have defined Economic Impact

Assessment (EIA) and identified the most common sorts of variables which are used in this type of

analysis, that it is possible to discuss the needs and make recommendations for the creation of an EIA

for SMEs information base.

3.1.1 Legal Framework

Croatian legislation recognises two main types of the business subject: legal and natural (physical)

persons. These two main categories are further sub-divided as illustrated in the Box below.

Box 1: Types of Business Subjects in Croatia

1. Legal business subjects:

a. General partnerships

b. Limited partnerships

c. Limited liability partnerships

d. Cooperatives

e. Limited liability companies

f. Simple limited liability companies

g. Stock companies

h. Economic interest associations

i. Clusters

2. Natural (physical) business subjects:

a. Crafts

b. Freelancers

Sources: Act on Companies (OG 111/93, 34/99, 121/99, 52/00, 118/03, 07/07, 146/08, 137/09, 152/11, 111/12, 144/12, 68/13), Crafts Act

(OG 73/93, 90/96, 102/98, 64/01, 71/01, (49/03), 68/07, 79/07, 40/10), Cooperatives Act (OG 34/11)

The basic division above leads to a definition of the institutions in charge for data collection (i.e. the

original sources of information). The collection of the majority of SME information is connected with

the annual financial reports (AFR) that companies are required by law to submit at the end of the

year, leading to the collecting of SME data.

The division of institutional responsibilities regarding such data is the result of the Tax legislation,

which requires that all business subjects paying Profit Tax must submit reports (i.e. submit AFRs) to

the Financial Agency (FINA). In other words, all legal business subjects and natural business subjects

with total revenues exceeding 230,000.00 HRK are required to report to FINA. All natural business


Service Contract No. IPA2007/HR/16IPO/001-021401

EIA database report- Draft

EIA database report - Draft

15

subjects that fall below this threshold are included in the Income Tax system and are required to

submitting AFRs to the Tax Office (rather than FINA).

Box 2: Division of the Business subjects regarding submission of the AFR

1. 1. Business subjects that submit AFRs to FINA: 2. 2. Business subjects that submit AFRs to the Tax Office:

All legal entities:

General partnerships, Limited partnerships, Limited liability

partnerships, Cooperatives, Limited liability companies, Simple limited

liability companies, Stock companies, Economic interest associations,

Clusters and Crafts and Freelancers with total income above

230.000,00 HRK

Crafts and Freelancers with total income below 230.000,00

HRK

This fundamental division has implications for the pool of relevant information: FINA covers

approximately 50% of companies (that are obliged to pay Profit Tax), whereas the other 50% is

covered by the Tax Office (that are obliged to pay Income Tax).

Box 3: Effects of the Legal Framework on SME information The legal framework is very significant for the existence of information in the Republic of Croatia. The main division of the business entities (legal entities and natural persons) defines which information business subjects must submit as a part of their annual financial report. AFR is the main source of information and all business subjects must submit it at the end of the business period. This period overlaps with a calendar year; crafts are required to submit their annual reports by the end of the March and legal entities by the end of the April. In line with this division, two institutions collect information annually, namely FINA and Tax Office. FINA collects information on all business entities obliged to pay Profit Tax. This includes legal entities (subdivided in line with the EU Small Business Act on micro, small, mediums size and large enterprises), cooperatives as a separate group of legal entities and some natural persons (“large” crafts and freelancers). The Tax Office collects information on all natural persons, also includes crafts that are obliged to pay Income Tax. The main problem regarding the existence of information is connected with this division. Legal entities and “large” crafts, which represent a bit less than 50% of business subjects, submit very detailed financial reports that include Balance and Profit/Loss tables (over 150 variables). This is a key source of detailed information, which allows all variables to be cross-tabulated. FINA estimates that about 95% of legal entities submit such information regularly (the remaining 5% submit reports after the deadline or do not submit them due to the bankruptcy process). Natural persons submit annual reports to the Tax Office. The fact that crafts are defined as natural persons affects the existence of information:

Natural persons submit a general report: few general variables are collected such as total income of natural person but cannot be subdivided by income from main activities, income from other sources, etc.

Related to this issue is also issue of identifiers: crafts do not have their own identifiers (i.e. all entities submitting reports to the Tax Office are defined by their Personal Identification Number or OIB), which all persons in Croatia have. Consequently, the owner of a craft has a same identification number as his/her craft (by contrast, legal entities have identification numbers, which are different to their owner). This causes a host of problems:

- The personal income of the craftsmen is submitted along with the financial results. It is not possible to separate income that craftsmen generate (e.g. income from part time work) from the income that craftsmen earned working in his/her craft. - If a person owns more than one craft he/she submits consolidated financial results (e.g. if a person has five different crafts, the craftsman submits one report for all his/her “private” earnings, as well as all five crafts together). It is not only impossible to separate income of the craft from other craftsmen’s incomes, but it is also impossible to separate individual incomes of each craft owned by a particular craftsman. - Issues related to the identifiers also cause problems in the case of inheritance or in the case when craftsmen decides to sell his/her craft. These two types of transactions are not registered as a change of ownership with continuation of doing business (i.e. as an existing company that just changed its owner). Because the craftsman’s identification number is the same as the crafts identification number, every change in ownership is statistically registered twice: the first time as a closure of the craft and the second time as a start-up of a new craft. This causes significant deviations from a real situation and artificially increases number of closed and opened crafts. - A craft owned by partners is registered on just one person (i.e. craft is associated with only one of the owners and his/her identification number). Every partner (co-owner) must submit a financial report registering only his/her part of the income from the craft. The person on whose name the craft is registered will only report share of the craft’s income equal to





16

his/her share in the craft (e.g. with three partners in the craft, the reported total income of the craft will be sub-divided into three parts, in line with their shares in the partnership). Thus, information on income is highly inaccurate yet is the only available financial information on crafts.

In addition, the Tax Office is collecting financial information for tax collection. The only information they are interested in, is total income of individuals, since this is the basis for taxation. No other institution collects financial information on crafts. It is not possible to find key information such as total expenditure, expenditure on employees, profitability, efficiency, etc.

All other institutions collect partial information in specific areas related to their scope of work (e.g.

Pension fund information on pension insurance, Customs Administration information on customs

etc.). All data are submitted to the Central Bureau of Statistics (DZS), which merges, processes,

analyses and publishes them.

3.1.2 RIA and EIA

Regulatory Impact Assessment (RIA) is a set of logical steps to be followed in preparing policy

proposals. This is a process that prepares evidence for decision-makers on the advantages and

disadvantages of possible policy options by assessing their potential impacts in general. The RIA

process includes the following steps:

Identify the problem and objectives; Identify policy options; Identify impacts of the options; Gather evidence; Assess impacts; Measures for compliance and enforcement; Measures for monitoring and evaluation; Prepare the RIA Report.

All these steps should include consultations with the beneficiaries, affected parties and interested public as is explained in the Impact Assessment Manual produced by BIZimpact I Project in September 2008 and in the new BIZimpact II EIA for SMEs Manual (2013). It should be noted that Economic Impact Assessment (EIA) represents a specific aspect of RIA that, as

suggested by the name, is focused on economic impacts. Therefore, EIA for SMEs follows the same

generic procedures as RIA but, due to its specific focus, also requires a more narrow, specialist set of

information compared with RIA in general. As defined in the EIA for SMEs Manual (2013), developed

by the BIZimpact II project, the main issues to be considered include:

Which sectors of the economy will be affected?

Which industries will be affected?

What are the employment characteristics of the affected sectors?

What is the recent/current economic performance of the affected sector (output, employment,

investment, trade)?

What is the market structure of the affected sector (competitive, concentrated, ease of entry)?





17

3.1.3 EIA Variables

RIA and EIA are tool to help policy-makers make better judgements. In undertaking EIA for SMEs the

institution or person implementing the IA must collect information, perform analyses and reach

conclusions with allow policy makers to differentiate between different policy options.

Such a decision is mostly based on qualitative information, observation of best practices, etc. but

should also include quantitative information to the extent that this is possible. It is not enough to

simply establish whether a law or regulations will affect certain groups of SMEs or not; ideally,

quantitative information will help determine issues such as how large that group is and how large will

that impact will be in relation to number of SMEs, number of employees, profitability, etc. We can

only establish this with the use of quantitative variables. If the qualitative part of analysis gives us an

answer to the question: “What will happen?”, the quantitative part gives us an answer to the

question: “How large will the change be?” Furthermore, whereas qualitative analyses are based on

opinions, presumptions and conclusions, quantitative information provides a much stronger basis for

those same opinions, presumptions, and conclusions.

However, in assessing quantitative information, we must recognise that the variables do not have

equal relevance and weight. In some cases, information on the sectorial or geographical distribution

of SMEs will be irrelevant; in other cases, it will be crucial. On the other hand, certain types of data,

such as the total number of SMEs that will be influenced by some change in law or regulations will

probably almost always be of relevance in EIA for SMEs.

As a general principle, quantitative information provides the policy analyst with additional dimension

and weight to conclusions and it is a matter of good practice to use this type of information

whenever possible.

Due to its focus on the assessment of a specific type of impact (i.e. economic impact), EIA usually

uses a recurrent palette of variables. The EIA should assess the likely impact of the proposed

regulation on economic performance of the affected sectors. The key indicators to be considered are

output, employment, investment and productivity. In each case, the impact can be estimated as the

change from the current or baseline level, which can be attributed to the introduction of the

regulation. In line with this, the main questions to be answered are:

What is the likely impact on employment?

What is the likely impact on output?

What is the likely impact on productivity?

What is the likely impact on investment?

The Table below highlights some of the key variables that would normally form part of an EIA for

SMEs information base.





18

Table 1: Key EIA for SMEs Variables

Variable Value of the variable in the context of the EIA

Number of Business Subjects Main variable for EIA (basic information on business entities). Number of Employees

Disability Information on specific areas of EIA (i.e. assessments on impact on specific target groups). Gender of owners/Main shareholders

Costs of Doing Business

Basic financial information that varies by type / size of enterprise, county, sector, etc. For example, the SME Observatory Reports1 show differences between micro, small and medium-size companies regarding average profitability, net income, tax burden, etc.

Turnover

Income (Gross/Net)

Profitability

Productivity (input vs. output values)

Investments (total, R&D, innovation etc.)

Taxation

National Insurance Contributions

(Sub)Divisions Value of the division in the context of the EIA

Legal type

The effects of laws and regulations impact differently on various types of business subjects. This is particularly apparent in relation to legal entities vs. natural persons, since the legislation and taxation is very different.

Size

Varying impact according to size classes of SMEs is to be expected. There is an increasing emphasis on the likely impact of the regulatory burden upon micro businesses (up to 9 employees).

NACE codes

Taking into consideration the heterogeneity of the country (exacerbated by its geographic form) varying NACE activities is expected, such as tourism / services in costal parts. This also applies to the sectorial division (e.g. manufacturing and industry in the continental parts, services in the coastal parts, etc.), as well as the geographical division (e.g. concentration of SMEs in and around the city /county of Zagreb).

Sectorial division

Geographical division

To improve the analysis, it is desirable to have the capacity to cross-tabulate the above variables.

It is important to note that information on specific groups such as female entrepreneurship,

disability, minorities, etc. is not available in Croatia at the level of the SME sector. Some information

does relate to gender but even these data are partial. For example, the Female Entrepreneurship

Strategy is based on estimates derived from focus groups and roundtable discussions.

Comprehensive information related to these groups, including in the area of SMEs, does not exist.

3.2 Sources of Information relevant for EIA for SMEs

Following the definition of the variables relevant to EIA for SMEs, after the meeting with experts

from the IAENL Project, internal meetings of the BIZimpact Project and consultations with Project

Manager and Coordinator at MINPO, the principal potential sources of information for the EIA for

1 The Croatian SME Observatory Report 2012, Project Improvement of Administrative Efficiency on the National

Level, http://server05.globaldizajn.hr/sme-observatory/UserDocsImages///Report%20cro-eng%20version.pdf

http://server05.globaldizajn.hr/sme-observatory/UserDocsImages/Report%20cro-eng%20version.pdf





19

SMEs information base were identified. Meetings were held (i.e. survey in the form of discussions

with all key data sources) in order to discuss sources, variables, quality, availability, etc. Although not

all the information identified in this report will actually find its way to the EIA for SMEs information

base, this report represents a useful guideline for those interested in the type of information that is

currently available in relation to the SME sector. It represents the most comprehensive document

currently available surveying the principal sources of information in the area of SMEs, defines the

variables collected by different institutions, their scope, frequency, methodologies, etc. Annex II lists

the meetings held on this subject, as part of the qualitative survey of the relevant institutions.

3.2.1 Ministry of Entrepreneurship and Crafts (MINPO)

The Ministry of Entrepreneurship and Crafts has three main Directorates, namely: Directorate for

SMEs and Crafts, Directorate for International Cooperation, Investment and Development, and

Directorate for EU Programmes and Projects, Bilateral Assistance Programmes and Other

International Institutions projects. About 85 civil servants work at MINPO, whose key policies

include:

Small Business Development Promotion Act; The Entrepreneurship Development Strategy 2013-2020; The Promotional Programme for SMEs 2008-2012; The “Poduzetnički impuls” (Operative Promotion Plan for SMEs, latest being 2013); Strategic Plan of the MINPO 2012-2014; Strategy for Entrepreneurial Learning 2010-2014; Strategy for Women’s Entrepreneurship Development 2010-2013; Cluster Development Strategy 2011 – 2020.

MINPO has a complex and demanding role to perform in supporting SMEs and there is a need to

develop further its capacity to perform its role, now that is has become the 28th member of the

European Union (EU). MINPO will play a comprehensive role in the future in relation to issues

covered by BIZimpact II, including:

Further develop and embed Economic Impact Assessment as far as SMEs are concerned; Strengthen the public-private dialogue and consultation process generally and for EIA for SMEs; Raise awareness and disseminate information among SMEs of key legislative areas; Develop stakeholders’ capacities for information / communication at national and regional levels.

MINPO manages two registers, namely the Register of Supports and Incentives for SMEs and the

Register of Crafts. Both registers are discussed below.

3.2.1.1 Register of Measures and Incentives for SMEs

This Register includes only SMEs and SME support institutions (enterprises, crafts, cooperatives,

BSOs, etc.) that have applied for MINPO’s projects of state incentives. Information is collected in

electronic form dating back to 2008. The type and quantity of information varies from project to

project, and have not been harmonised for all projects (i.e. different information is collected for

different projects so those information are just partial). There were previously 12 projects of support





20

but since 2013 there have been four measures with sub-activities since implementation of new

“Poduzetnički impuls” (Entrepreneurial Impulse) Programme, which is more comprehensive with

requirements of EU structural funds. These four programmes collect different data, based on the

focus, criteria and nature of the application forms (e.g. until 2013, information on the gender of the

owner of the enterprise/craft was collected exclusively for the project of Female Entrepreneurship).

The fact that is it not comprehensive and consistent across different projects and timescales means

that its usefulness for the EIA on SMEs information base is extremely limited, for example to certain

types of analysis of SME incentives.

MINPO recognises the current limitation of the Register of Measures and Incentives for SMEs and is

seeking to improve the register via its Strategic Plan 2012-2014.

Box 3: MINPO’s Strategic plan 2012-2014

“Phased introduction of the Central Register of merging, upgrading and new software systems, cooperation with regional

development agencies and their local coordination should be implemented in order to create a branched network for

support to businesses and craftsmanship that is easily accessible for the entrepreneurial needs. The system register that

supports small businesses is continually being improved and upgraded in order to have a simpler, quicker and cheaper entry

in the Register of aid, computerization of business processes and transparency in the allocation of state aid.”

MINPO’s Strategic Plan 2012-2014, p.17

Consequently, should the planned investment be realised, the quantity and quality of information

contained in this Register are likely to increase over time.

The type of data available through the Support Register of Measures and Incentives for SMEs is

illustrated in Annex III.

3.2.1.2 Register of Crafts

The crafts register system, developed for the former Ministry of Economy, Labour and

Entrepreneurship (MINGORP) has been used since 1996. Until 2003, the Register of Crafts was not

connected with the offices that collected information on Crafts (i.e. offices where crafts had to

register as a business entity and all information were inputted manually). This caused inconsistencies

and overlapping. Therefore, reliable crafts data in this register were available until 2003 when the

Register was connected with 108 offices of the Ministry of Public Administration that collect

information on crafts’ registration. The system currently consists of:

Office application;

Administrative and help desk application;

On-line register search engine (http://or.mingorp.hr);

Service for establishing a trade/craft and registering changes over the Internet (http://e-

obrt.mingorp.hr);

Application for records of household business activities and secondary occupations; and

http://or.mingorp.hr/

http://e-obrt.mingorp.hr/

http://e-obrt.mingorp.hr/





21

Automated service for data exchange with external institutions.

The central Register of Crafts on the Internet is a web application available to the public for search

and display of data of crafts/trades registered in Croatia. An important feature of this application is

the ability to view and print excerpts from the Crafts register, used by many government’s

institutions, financial institutions and the private sector.

All crafts must register in this database. Information that can be extracted from the register includes:

Total number of registered crafts;

Total number of active/inactive crafts as well as reasons for their inactivity;

Total number of start-ups and closed crafts;

Division of all crafts based on the Nomenclature statistique des activités économiques dans la

Communauté européenne (NACE) code;

Number of legal2 entities engaged in craftsmanship;

Total number of home crafts;

Number of secondary occupations.

MINPO’s Crafts Register presents a comprehensive overview of the total number of crafts. Since it is

an administrative register, key changes must be reported to the Crafts register in two main cases,

namely when a craft is registered and/or closed. This feature makes it a good data source for the

current number of crafts, births and deaths, however, other information is not so reliable. There are

also weaknesses, such as to do with specific information requested from the craftsmen when they

are opening a craft (e.g. gender of the owner). Although data are added to the application, they

cannot be extracted in the form of reports, excel sheets, etc. There are other limitations of a similar

nature, which could be corrected through an upgrade of the application.

All data contained in the register are collected by the offices authorised by MINPO for this work,

except for information on the number of employees, which is submitted by the Croatian Office for

Pension Insurance (see 3.2.11 Register of Pension Payments below). The information is updated on a

monthly basis.

Based on MINPO’s plans further improvements of this register, as well as its reach (such as collection

of more information for every application and harmonisation of all application forms) and data

quality are expected (numerous reprogramming requests hay to e been made in 2013, including the

capacity to extract additional variables).

Box 4: Entrepreneurial Impulse 2013

MINPO is up-grading the Crafts Register System via new modules and programmes to allow simple, fast and cheap

registration in the Crafts Register. Attention is paid to implementation of new technological solutions with an accent on

internet-based technologies. The connection with the Ministry of Justice and Ministry of Finances has enhanced the

2 Usually, crafts are physical entities. All legal entities must have permission to define themself as a craft. This is approved

only if the legal entity performs its business as a craft (majority of work being of a manual nature, no industrial processes, etc.).





22

efficiency of the system. Connection of the Crafts Register with the Croatian Academic and Research Network (CARnet) IT

system is under implementation. CARnet will allow on-line access to the information held in the Crafts Register and

registration bodies so as to register free “.hr” domains when new crafts are in the process of being registered.

The type of data available through the MINPO’s Crafts Register is illustrated in Annex IV.

3.2.2 Croatian Agency for Small Enterprise and Investment (HAMAG INVEST)

HAMAG INVEST’s activities include promoting the establishment and development of small business

entities, promotion of investments in small business, financing of operation and development of the

small business entities by crediting under favourable conditions and by other forms of financial aids,

giving guarantees for loans, giving aid for employment stimulation, vocational training, re-training

and additional training of workers, giving aid for research, development and modern technologies

application, as well as performing other operations entrusted to it by MINPO. HAMAG has three main

departments, highlighting its wider range of responsibilities:

Department of Financial Support via Guarantees: the promotion of SMEs is HAMAG’s primary goal and guarantees are issued to facilitate access to financing for SMEs that lack sufficient collateral;

SME Development Department: implements projects to foster a favourable entrepreneurial environment, promoting competitiveness and entrepreneurship, as well as developing business infrastructure. Grants co-finance SME investment, promote entrepreneurship in target groups (women, young, start-ups, disabled persons, etc.), and development of crafts and cooperatives;

Department for Financial Support via Grants: as an Intermediate Body, it will be in charge of implementing the projects financed from the EU Structural Funds, as defined by the Regional Competitiveness Operational Programme.

HAMAG INVEST is a recent development, which integrates the investment function with other

developments such as encouraging entrepreneurship, grants, entrepreneurial infrastructure,

Entrepreneurship centres, Regional Development Agencies, business incubators, technology parks,

enterprise zones and free zones. HAMAG INVEST will merge with the Business Innovation Centre of

Croatia (BICRO) during 2014, thus adding innovation to its palette of responsibilities.

HAMAG INVEST has three information bases: 1. Register of supports: this is a MINPO application used by HAMAG INVEST, which is connected with

MINPO (see 3.2.1.1 Support Register of Measures and Incentives for SMEs above);

2. Register of certified business advisors: information on business experts holding a HAMAG

certificate;

3. Register of guarantees: information on number of guarantees approved by HAMAG INVEST.

However, none of these databases is relevant to EIA for SMEs.

The type of data collected by HAMAG INVEST is illustrated in Annex V. The two most frequently

requested HAMAG INVEST SME supports are Requests for Guarantee and Letters of Intention.





23

3.2.3 Croatian Chamber of Economy (HGK)

The Croatian Chamber of Economy (HGK) operates as an independent organisation of all legal

entities engaging in business. Membership is obligatory under law for all enterprises. HGK consists of

the Headquarters office in Zagreb and 20 county chambers. Among these, the Zagreb Chamber

represents both the City of Zagreb and Zagrebačka County. HGK consists of eight Departments

dealing with the different branches of the economy and includes 40 professional associations, 87

groups and 19 affiliates. Within HGK, there are five business centres, Permanent Arbitration Court,

Conciliation Centre, Court of Honour and HGK Office for Areas of Special State Concern. HGK includes

a range of specialist institutions, including the Entrepreneurship, Innovation and Technological

Development Centre, the EU Centre and the Enterprise Europe Network.

HGK potentially covers all legal business entities, as well as a significant number of sub-sectors such

as the Economic Department, Industrial Sector, etc. On the other hand, communication with HGK

indicates that HGK does not have any specific information on SMEs. Discussions with HGK reinforced

the point that although information is collected from different sources, HGK does not produce any

information itself. Most information comes from FINA, DZS (see below) and export/import

information from the Customs Administration. Information on the start-ups is sometimes compared

and supplemented with the Trade Register information (i.e. information from the Trade Court).

The type of data available through the HGK is illustrated in Annex VI.

3.2.4 Croatian Chamber of Trades and Crafts (HOK)

The Croatian Chamber of Trades and Crafts’ (HOK) tasks include promoting trades and crafts,

representing tradesmen and craftsmen’s interests (some 84,000 members) vis-a-vis state authorities

and in the forming of economic policies, providing state authorities with opinions and suggestions

when passing regulations concerning trades and crafts, founding commissions for apprentice and

master’s exams, tradesmen and craftsmen’s activities, founding of the arbitration council, keeping a

Register of tradesmen and craftsmen, keeping a Register of apprenticeship contracts, assisting

tradesmen and craftsmen in establishing and operating trade/craft businesses, etc. Membership of

HOK is obligatory by law. The HOK network covers the whole county, except for Zadarska and

Šibensko-kninska counties.

Initial correspondence between the BIZimpact II project and HOK led to the conclusion that HOK does

not have any additional information, other than what is already collected through MINPO’s Crafts

Register. However, an analysis of HOK’s publication “Crafts in Numbers” and the variables reported

therein indicate that this was not necessarily the case. Information related to crafts, which represent

over 50% of SMEs in Croatia, is collected by the HOK publication (e.g. number of apprentices, master

exams for crafts, county distribution of all variables, etc.).

A meeting with HOK representatives indicated that the main basis for their information is indeed

derived from MINPOs Crafts Register. The Crafts Register is downloaded from the MINPO server on a

daily basis, checked and then added to the HOK information base. A second source of information is





24

the Ministry of Finance. Information from both sources is merged into the resulting “Book of Crafts”.

This database represents most comprehensive information on the crafts sector in Croatia:

1. HOK knows who its members are, exactly which business entities they have to request

information collected by the Ministry of Finance (all available financial information);

2. The Book of Crafts integrates all the available information on crafts;

3. The Book of Crafts excludes other business entities such as freelancers, unlike all other sources of

information on crafts;

4. Although crafts are treated as natural persons, the Book of Crafts separates crafts from the

universe of information on natural persons.

As such, the information contained in the Book of Crafts is the most accurate and comprehensive

source of information for close to half of business sector. Although MINPO’s Register of Crafts is the

original data source, its weaknesses are removed, to the extent that this is possible, by merging it

with all other data sources on crafts in Croatia.

The type of data available through the HOK is illustrated in Annex VII.

3.2.5 Croatian Employers’ Association (HUP)

The Croatian Employers’ Association (HUP) is a voluntary, independent and non-profit association

established on the principle of unconstrained membership and principles of democratic

representation of members’ will. HUP promotes entrepreneurial spirit and entrepreneurial rights and

freedom and is currently celebrating its 20th Anniversary. As an association, HUP participates in

collective negotiations and entering into collective agreements. HUP represents 4-5,000 members

who employ around 400,000 employees. Apart from labour and social legislation, HUP is also

engaged in regulations on industrial relationships, protection of private ownership, promotion of

development and settlement of market terms and conditions, strengthening of competition and

entrepreneurial climate. HUP has three regional branches in Rijeka, Osijek and Split (a fourth in

Varaždin is about to open), and 29 sectorial associations. Each of them has its own executive board,

and each sectorial association activities or activities of a group of sectorial associations are managed

by HUP professionals, including an SME Association. HUP also chairs the Non-Regulatory Working

Group connected with RIA / GLO.

Correspondence and a meeting with HUP led to the conclusion this it does not collect any

information or implement research that could be included in the EIA information base. If required,

HUP buys FINA data (Annex IX). HUP’s information base is limited to its members and, in contrast to

other key business associations, membership is voluntary. For this reason, even if HUP had additional

data, their reach would be limited to a few thousand members, compared to over 160.000

enterprises, crafts and cooperatives in the country.





25

3.2.6 Croatian Association of Cooperatives (HSZ)

The Croatian Association of Cooperatives (HSZ) represents cooperatives, cooperative associations

and other members that promote the individual and mutual interests of cooperatives. Based on the

Cooperatives Law (2011), there are over 1,000 registered cooperatives with about 18,000 members.

HSZ was established in 2002 and has responsibility for the development of the existing cooperatives,

as well as managing the Cooperatives Register. HSZ is effectively a chamber of commerce for the

cooperative sector. All new and existing cooperatives are required to register in the information

base. About 60% of HSZ’s budget is supplied by MINPO, which is the ministry responsible for the

cooperative sector in addition to SMEs and crafts. The HSZ’s main services include database

management; analysis of the sector (annual reports); education and training; information provision;

marketing and promotion of cooperative production; legal and accounting support, etc. Five staff are

located in the HQ in Zagreb and one in Rijeka.

HSZ has a database with key information on their members, however, the rest of its information

needs, such as for publications and analyses, is bought from FINA (see Annex IX). Although HSZ has

tried to undertake research on the cooperatives sector, the results have been disappointing (for

example, the questionnaires circulated typically receive only 2-3 responses).

Discussions with HSZ showed that its key sources of information are:

DZS: main NACE activity of cooperatives;

Trade Court: confirmation of registration, contact information and all NACE activities;

FINA: financial information.

Every cooperative must also submit a registration form to HSZ, but most of the information is already

collected from different sources. Additional information is collected, which is mostly relevant to HSZ

such as the degree of processing (raw materials, semi-finished and finished products), trademarks

and/or certificates, key products/services, awards and membership in associations. Upon

registration, the up-dated form is submitted to HSZ annually.

The type of data available through the HSZ is illustrated in Annex VIII.

3.2.7 Central Bureau of Statistics (DZS)

The Central Bureau of Statistics (DZS) is the national statistical institution. DZS is independent in its

work and seeks to harmonize its activities and methodologies with the statistical agency of the

European Union (Eurostat). DZS collects information from different sources (e.g. FINA, Tax Office,

REGOS and Customs), merges and processes it in line with the EU directives in order to ensure

compatibility, benchmarking and comparability with the other 27 EU member states. DZS also

undertakes research, mostly related to employment matters. The list of variables collected by DZS is

extensive so it is more effective to list the originating institutions for DZS and variables collected:

FINA: all FINA variables (Annex IX); enterprises, cooperatives and crafts in the Profit Tax System;

Tax Office: all Tax Office variables (Annex X), all information on all subjects in the Income Tax

System;





26

The Central Register of Affiliates (REGOS): information on number of ensured persons, employees,

payers of pension insurance;

Register of pension system: information on users of pensions, child and social support;

Employment office: information on unemployment;

Customs office: information of import and export of goods;

Croatian National Bank: information on import and export of services, macroeconomic

information.

Not surprisingly, DZS represents the most comprehensive source of information on SMEs. The

fundamental problem, however, is that the DZS criterion for SMEs is not fully aligned with MINPO’s

criterion of legal business entities. DZS separates legal entities regarding number of employ,

however, MINPO must include other criteria in line with Small Business Development Promotion Act,

including total turnover and profit. Although DZS has the capacity to make such divisions, but since

these types of tables are not created “by default” as a part of DZS regular activities, the creation of

tables in line with the additional criteria would involve significant time and other resources. Now that

the Republic of Croatia is a member of the EU, DZS will be required to report to Eurostat on a

consistent basis. This requirement means that more information on SMEs should be available in the

future. However, this will not happen in time to be included in the EIA for SMEs.

3.2.8 Financial Agency (FINA)

The Financial Agency is the leading institution in the field of financial mediation and the application

of information technologies to meet statistical users’ requirements. FINA is an Agency of the Ministry

of Justice; in other words, they are not a statistical institution, rather their services focus on the

collection of information specifically for the needs of the Ministry of Justice. FINA’s key advantages

include national coverage, sophisticated information system and professional expertise. Based on

those strengths, FINA is able to carry out a broad range of projects, ranging from analysis of simple

financial transactions to the most sophisticated of analyses. Furthermore, with its extensive branch

network, FINA covers the entire territory of Croatia.

Information is collected on annually when business subjects that pay VAT submit their annual

financial reports. Deadlines for submission of reports are prescribed in the Accounting Act. The

system for data collection is opened continuously but business subjects that submit reports after

deadline are in violation of the act. FINA estimates that over 95% of business subjects submit their

reports within the deadline and their assumption is that rest of 5% business subjects are likely to be

undergoing the bankruptcy procedure.

FINA represents a rich source of information since it collects at least 156 variables, while some

enterprises are submit even more comprehensive data (302 variables). Besides annual financial

reports, FINA also collects information on non-liquid, insolvent business subjects and business

subjects engaged in the bankruptcy process.





27

While all this information is very detailed the key weakness is that FINA data only cover half of

existing SMEs (i.e. the data do not cover the vast majority of crafts, except for the largest 5,000 crafts

with turnover of over 250,000 HRK over a two-year period). Nevertheless, it represents the main

source of information on all legal entities, cooperatives and crafts within the VAT system. It is

possible to extract information on total number of legal entities, employment, profitability, regional

distribution, etc. All information is available as a time-series and at the NACE 4-digit level and it is

possible to cross-tabulate the entire information base.

The type of data available through the FINA is illustrated in Annex IX.

3.2.9 Tax Administration

The Tax Administration is an organisation within the Ministry of Finance whose task is to implement

tax regulations and regulations concerning the payment of obligatory state contributions. The Tax

Administration collects information specifically on “physical entities”, which includes all individuals,

freelancers as well as all Crafts that are not included in the VAT system. As such, it supplements the

information collected by other institutions such as FINA. A problem with information on Crafts arises

from the fact that they are equal to their owners; in other words, the indicators used for a person,

namely their identification number, is the same for their craft, making it impossible to distinguish the

individual from the business activity. Furthermore, a craftsman may have several crafts but all the

information would be aggregated at the level of the single identification number.

Although the intention was to visit the Tax Administration, the meeting APIS IT (see 3.2.10 below)

demonstrated that this was not required, APIS IT processes all the Tax Administration’s information

and is familiar with the relevant issues related to the data processing. The information collected by

the Tax Office is, therefore, described in the section below.

The type of data collected by the Tax Administration is illustrated in Annex X.

3.2.10 Agency for support to IT systems and technologies (APIS IT Ltd)

The Agency for Support to IT Systems and Technologies (APIS IT Ltd) was established in 2005 via a

contract between Republic of Croatia and City of Zagreb in order to develop and support key

information systems in Croatia and Zagreb, to develop application services and keep databases as a

means of effective administration. APIS IT participates in projects such as computerisation of the

largest state and city administration systems, implementation of OIB, EU projects of Customs and Tax

administration, etc.

In the context of the EIA information base, APIS IT is of notable relevance, since it processes all

information collected by the Tax Administration (See Annex X). APIS IT Ltd manages the internal

(unofficial) Register of Physical Entities for the needs of the Tax Administration. Discussions with

APIS IT Ltd confirmed that it is possible to separate information on crafts from other information

related to other physical persons. Information from this register is used exclusively for the needs of





28

the Tax Administration, but this is not shared with others. However, it is possible to obtain the

information with the prior approval of the Tax Administration’s.

Nevertheless, APIS IT Ltd highlighted a number of limitations with the accuracy of information:

The Register has unofficial character (i.e. it gives just an orientation to the Tax Administration

regarding different subdivisions). Information related to crafts as a separate form of physical

persons is not necessarily accurate. The Tax Administration is interested in information related to

the payment of taxes and they can only guarantee that information of total income of some

individual is correct. It is hard to separate share of an individual’s income from craft activity or

income of separate crafts if an individual owns more than one craft.

The Tax Administration enters all tax information manually. For example, the NACE code is

written in a descriptive form. Staff then connect these descriptions with the relevant codes and

enter these values. This process leaves scope for inaccuracies to arise.

The Register is not linked with MINPO’s Crafts Register, so it is not possible to check the accuracy

of the number of crafts, number of owners, number of partnerships, number of separate

facilities for performance of the craft’s activities, etc.

In the context of accuracy of information on crafts, APIS IT Ltd noted HOK’s Book of Crafts as

being the more reliable source of information. It was noted that good cooperation with HOK,

which “cleaning” all information received and sends feedback on mistakes found in APIS’s

information.

The Tax Administration’s Register (maintained by APIS) will gain in usefulness when it is connected

with the MINPO’s Crafts Register in relation to the possibility to cross-reference APIS’s information

with MINPO’s Crafts Register as an official register of crafts. It will be then be possible to compare

Tax Administration’s Register with the original source of information, double-check the data and

correct mistakes. Plans for this connection started few years ago but the lack of finance has

constrained further development.

The type of data collected by APIS IT Ltd on behalf of the Tax Administration is illustrated in Annex X.

3.2.11 The Central Register of Affiliates (REGOS)

The Central Register of Affiliates (REGOS) is an institution founded by a Regulation of the

Government of the Republic of Croatia (Official Gazette 101/99), with the aim of providing technical

support for the second pillar of pension insurance under the Central Register of Affiliates in the

Republic of Croatia.

Box 5: Croatian Pension System

The pension system was significantly changed in 2001/2002, resulting in a mixed, state-private financed, system.

The new Pension System consists of three “pillars”, the first two of which are mandatory and the third is voluntarily:





29

The First Pillar is based on inter-generational solidarity. All employees are obliged to contribute to this pillar with 15%

of their gross salaries. This is transferred to the Register of Pension Payments and current pensions are paid from this

source. Pension accrued cannot be transferred to another person or be inherited.

The Second Pillar is pension insurance for “old age” based on capitalised savings. It is mandatory for all insured

persons younger than 40 years and the contribution to this pillar is 5% of the gross salary. The second pillar is

mandatory for all insured persons but the pension fund can be selected in REGOS and FINA.

The Third Pillar is voluntarily pension insurance based on the individual capitalised savings. The value of the pension

from this pillar is based on the cumulated value of all monthly payments to the pension fund. The Pension fund invests

and the profits, if any, are cumulated. An incentive to participate in the third pillar is provided by the state (25% of

money saved by the insured person annually up to 1.250,00 HRK). The capital from the third pillar can be withdrawn

even before the insured person reaches pensionable age.

Source: Webpage http://limun.hr/main.aspx?id=12478&Page

REGOS holds information on number of employees for all business entities, legal and physical,

because all employees must be insured. REGOS collects the Information and processing is performed

by APIS IT Ltd (see 3.2.10 above).

Discussions with REGOS confirmed that all their information is also available to DZS. The REGOS

register it is not able to separate business subjects regarding size. MINPO considers REGOS as the

most reliable source of information on number of employees and uses its information in the

evaluation of applications for state support but all this information is at the individual level (i.e. for

each state support applicant, MINPO asks individual information). As mentioned above, the issue

that, for the needs of the RIA process, MINPO needs aggregated information but it is not possible to

aggregate it at needed level (grouping regarding legal type, size, NACE code, etc.).

The type of data available through REGOS is illustrated in Annex XI.

3.2.12 Register of Pension Payments (HZMO)

The Register of Pension Payments (HZMO) is a public institution established by the Pension Insurance

Act and is the legal successor of ex Republic Pension and Disability Insurance Funds. Data collected by

HZMO is overlapping in some areas with information collected by REGOS, but while REGOS is focused

on payers of fees for pension funds (i.e. employed persons), HZMO is focused on current users of

pensions and, related to employment, social rights that arise from this status, such as the recipients

of child support.

Discussions indicated difficulties in extracting SME-related information. Although HZMO sends its

information regularly to the Ministry of Labour and Pension System, Crafts Register, HOK and DZS

regarding number of employees in crafts, such information are not 100% accurate. Namely, persons

can be insured on just one basis (i.e. just on one working place, but previously noted, it is possible

for a person to be employed at one or more places and have multiple crafts). The information and

experience available indicates that the number of persons falling into this category is significant,

resulting in data accuracy concerns.

http://limun.hr/main.aspx?id=12478&Page





30

The type of data available through HZMO is illustrated in Annex XI (same as REGOS).

3.2.13 SMEs and Entrepreneurship Policy Centre (CEPOR)

CEPOR is a non-profit organization dealing with the problems of the SME sector. CEPOR’s areas of

work include research, policy development and advocacy such as production of the Global Enterprise

Monitor (GEM) report since 2001, Strategy of Women Entrepreneurship Development for MINPO,

contributing to the SME Development Strategy 2013-2020 and publishing an annual SME Report

among other activities. Due to this involvement, CEPOR is a potentially useful source of information

for the EIA for SMEs information base, as well as source of information on additional potential

sources of information that was not directly of relevance to the BIZimpact II Project.

CEPOR is implementing the Global Entrepreneurship Monitor (GEM) research in Croatia (financed by

MINPO), which is an important source of enterprise information. The rest of information is collected

in less formal manner, such as focus groups and round tables.

The meeting with CEPOR demonstrated that they are not collecting any information relevant to the

EIA for SMEs.

3.2.14 Economic Institute, Zagreb (EIZ)

The Institute of Economics is a public scientific institute founded in 1939 with a longstanding

tradition in conducting economic research and sectorial analyses, including experience of working

with SMEs. The Institute of Economics is closely involved in the work of MINGORP/MINPO, such as

the definition of indicators for future SME support/incentives projects, the new MINPO’s Strategy of

SME Development 2013-2020, Report on SMEs 2012, etc.

The meeting at EIZ showed that this institution does not collect and information on SMEs and

research that is not necessarily related to the area of SMEs.

3.2.15 IPA Project Improvement of Administrative Efficiency on National Level (IAENL)

The Improvement of Administrative Efficiency on National Level (IAENL) project aimed to strengthen

the policy-making capacity of the MINPO through the provision of improved information on SMEs

and their needs, and to enhance the abilities of MINPO staff to contribute to the development of

more effective policies to support and strengthen SMEs. IAENL implemented a number of actions:

Support to further develop the MINPO supports register;

Assisting MINPO and HAMAG in the preparation of SME Observatory Reports;

Procedures to allow the effectiveness of MINPO financial assistance to be measured;

Collection of information on the SME sector through business surveys;

Assessment of impact of EU accession on Croatian SMEs, etc.

A key output was preparation of the SME Observatory Reports:

1. Croatian SME Observatory Report 2012: This was the first comprehensive overview of the SME

sector. It included an overview of the macroeconomic situation and of the SME sector. As the





31

first report on the SME sector, it set benchmarks based on data from 2008 and 2010. These dates

reflected the Croatian SME sector at its peak (2008) and during the global economic crisis (2010).

2. Croatian SME Observatory Report 2013: As its legacy, IAENL had to leave a basis for future SME

Observatory Reports, therefore, the structure of the report was changed. It made use of less

information but was drafted to be aligned with Eurostat’s methodology in order to make all

information comparable with the data from other EU countries members.

The IAENL project also published the following reports:

Assessment of the Impact of EU Accession on Croatian SMEs;

National Grant Schemes to Promote SME Development 2008-2011: An Independent Survey;

Survey of the Administrative Obstacles for SMEs.

3.3 Summary of Available Data

This chapter has illustrated that there is a large number of data sources relevant to the SME sector in

Croatia. A summary of the institutions, nature of their information and available SME variables is

given in Table II.

Table II: Summary of key relevant data

Institution/Register Scope of information Available information/variables

Support Register of Measures and Incentives for SMEs

SMEs, crafts, co-operatives and BSOs that have applied to MINPO’s tenders for grants (around 10% of existing enterprises in Croatia).

Non-financial information: total number of enterprises that applied for grants, county distribution, age, gender, etc. NOTE: Variables in the information base does not cover all entities in the information base (i.e. there is no a single form for application so different information is collected for different projects (e.g. age – only for start-ups, gender – only for female entrepreneurship, etc.). Due to the small number of enterprises covered (around 10% of existing SMEs), the information from this register is not suitable for EIA for SMEs.

Crafts Register All crafts in Croatia (every craft must register in MINPO’s Crafts Register)

The main information is number of: active crafts on a specific date, start-ups, closed crafts, active crafts regarding NACE 2007 (major activities), legal entities engaged in crafts, domestic cottage industries and secondary occupations. The Crafts Register is not connected with any other source of information on crafts (e.g. Tax Administration and HZMO).

HAMAG INVEST

Register of Supports, Register of Guarantees approved by HAMAG INVEST and Register of Certified Business Advisors

HAMAG INVEST does not collect information relevant to EIA for SMEs.

Croatian Chamber of Economy (HGK)

Register of Legal Entities (approximately 50% of Croatian business subjects)

HGK does not produce data (i.e. it collects information produced by other institutions such as FINA and Croatian National Bank (HNB).

Croatian Chamber of Trades and Crafts (HOK)

All Crafts in Croatia (every registered Craft must be a member of HOK)

Non-financial information: number of crafts, main NACE activities, regional distribution, number of craftsmanship pupils, number of apprentices, master exams, etc. HOK is not the original source of information but the Book of Craftsmen represents the most comprehensive source of information on crafts.

Croatian Association of Cooperatives (HSZ)

Register of Cooperatives (every registered co-operative must be a member of HSZ)

HSZ information is based on FINA data. HSZ does not collect any additional information on cooperatives.

Central Bureau of Statistics Statistical institution that covers all Information collected by FINA, Tax Administration, REGOS,





32

(DZS) business entities, as well as NGOs, non-profit organisations and state institutions. Most comprehensive source of information on the economy as whole.

Register of pension system, Employment office, Customs Administration and HNB merged into one register. DZS variables are calculated for the entire economy and they are not suitable for EIA for SMEs (i.e. variables include large enterprises).

Financial Agency (FINA)

Annual financial reports of all legal entities and crafts/freelancers with annual turnover greater than 230, 000 HRK/30,667 €

Non-financial information: number of enterprises, number of employees and county distribution. Most important financial information: turnover, profit, export, import, assets and investments. All financial information can be further subdivided (e.g. long term and short-term assets, investments in long term and short term assets, etc.). All information can be also cross tabulated.

Tax Administration Collects information on all physical entities.

Financial and non-financial information: total number of physical entities doing business, income from employment (“dependent work“), income from self-employment, income from property and property rights, income from capital, income from insurance, other income, foreign income, total income, taxes and surtaxes, information on relief, exemptions and incentives. The problem arises from identifiers, which are the same for individuals and their crafts. It is not possible to separate incomes (e.g. private income of the craft’s owner and income of the craft); if individuals have more than one craft, they submit only a consolidated report, etc.

Agency for support to IT systems and technologies (APIS IT Ltd)

Processing information collected by Tax Administration

The Central Register of Affiliates (REGOS)

Employment information Full number of employees in Croatia, covers all entities, possibility to extract information regarding type of enterprise (size and legal form).

Register of Pension System Users of pension system (current and future), users of child support

Register of Pension System does not have/collect any information relevant to EIA for SMEs.

SMEs and Entrepreneurship Policy Centre (CEPOR)

Global Entrepreneurship Monitor (GEM) Research

Variables used in the GEM Research such as TEA index. No relevance for EIA for SMEs due to the limited number of persons included in the research and the fact that they are not collecting information on existing enterprises.

Economic Institute, Zagreb (EIZ)

Economic Institute does not have/collect any information relevant to EIA for SMEs

Economic Institute does not collect information relevant to EIA for SMEs.

Improvement of Administrative Efficiency on National Level (IAENL) Project

Summary of data on SMEs published in SME Observatory Reports 2012 and 2013; information merged from different sources (mostly FINA and DZS)

DZS and FINA variables (mostly used separately due to their partial incompatibility). The IAENL project ended in 2013 and it is not clear if SME Observatory Reports will continue.

Table II illustrates the existence of numerous organisations relating in one way or another to the SME

sector. This fragmented institutional situation has a number of implications:

The above institutions collect partial information in line with their specific remit;

There is a lack of coordination and cooperation between different institutions in relation to data

for the SME sector. This lack of coordination and cooperation may even apply within institutions.

For example, within DZS, where differences exist between the Administrative and Business

Registers and the NACE codes of business subjects vary in institutions such as FINA and DZS;

The institutions apply incompatible methodologies. For example, HZMO uses one methodology

when processing information for itself, another when submitting information to the Employment

Office and a third when submitting information to DZS. This results in incompatibility of

information, inefficient use of resources and frustration for end users of statistical information;

The key data source that could be used as a coherent and consistent source of information is

DZS. However, the problem is that the methodology used by DZS is not in line with MINPO’s

needs. In other words, the definition is based on the Accounting Act, means that legal entities

(micro, small and medium size enterprises) only use the number of employees criterion, rather





33

than the Enterprise Act definition, which covers two additional criteria for division of enterprises,

namely total turnover and total assets. However, accession to the European Union and the

requirements of Eurostat means that this problems is likely to be resolved in the short to

medium term, resulting in greater range of SME data available.





34

4. CONCLUSIONS AND RECOMENDATIONS

The BIZimpact II Project undertook the following activities:

Identified the legal framework for doing business due and its connection with data collection, analysis and publication;

Defined an indicative list of the potentially most useful variables and sub-divisions from and EIA for SMEs perspective;

Identified all potential sources of information for the EIA information base and organised meetings as part of the survey of sources;

Prepared an overview of the existing information (i.e. variables and sub-divisions of relevance to EIA for SMEs).

The rest of this chapter summarises main conclusions and presents the recommendations for the actual development of the EIA for SMEs information base. It should be noted that the next step will be to finalise the report and implement the EIA for SMEs information base. During a later stage of implementation of the BIZimpact II Project, the resultant EIA for SMEs information base will be connected with the Virtual Centre of Excellence on EIA for SMEs.

4.1 Conclusions

Following structure of the Report, the main conclusions cover the three main areas described in the

report, namely: the legislative framework data availability, the sources of information for the EIA for

SMEs information base and the main variables for the EIA for SMEs information base.

Legislative framework for data availability

The legislative framework directly defines the availability of information on SMEs:

The Crafts Act defines crafts as physical persons and not as legal business entities;

The Profit Tax Act and Income Tax Act define which categories of business subjects are required to

submit annual financial reports to which institution. Legal business subjects and some physical

persons obliged to pay Profit Tax submit annual financial reports to FINA and the majority of

physical persons to the Tax Office (the threshold is 230.000,00 HRK of income. Physical persons

with an income larger than 230.000,00 HRK are included in the Income Tax system, this

represents only around 5% of crafts);

SMEs can be divided into three separate groups: legal entities (additionally sub-divided by micro,

small and medium size enterprises), cooperatives and crafts. Two of these groups of enterprises

submit annual financial reports to FINA and the other (95% of crafts) to the Tax Office;

The Tax Office is not interested in the collection of statistical information. Where it does collect

information, it is solely to establish the basis for payment of taxes, with the consequence that

there is limited information available on 95% of crafts. The reason is that annual financial reports

to the Tax Office are much more general than those submitted to FINA;

The most obvious and systemic gap in information concerns the crafts sector, which is a direct

consequence of the current legal framework.





35

Main variables for the EIA for SMEs information base

Qualitative information for policy analysis should whenever possible be supported with quantitative

information to address issues such as: how large is the target group, which groups or sub-groups will

be affected, in which region, etc. Without numbers, policy-making remains largely opinion-based

rather than evidence-based. Based on this rationale, the most notable ones include the following:

Number of Business Subjects;

Number of Employees;

Costs of Doing Business;

Turnover;

Income (Gross/Net);

Profitability;

Productivity (input vs. output);

Investments (total, R&D, innovation etc.).

SMEs and Sources of information

Numerous institutions are in charge for data collection, though none is dedicated to the collection of

data on SMEs. In line with MINPO’s Strategy and newly adopted amendments of the Small Business

Development Promotion Act, MINPO is required to develop a Register (Central IT System of SMEs), a

process which is underway. The Ministry is also improving the Register of Supports and the Crafts

Register and the potential and usefulness of these databases increase over time. Upon accession to

EU, DZS will have to submit detailed information to Eurostat on SMEs. Overall, although the number

and quality of SME data is improving, it remains inadequate.

A weakness in the current legislation is that it equates “regular” physical persons with craft as

physical persons. In practice, this means that the number of variables on crafts is very low (i.e. there

is almost no relevant information on crafts except for number of crafts, number of employees and

total turnover). This is serious gap in information, since crafts represent 50% of SMEs. By contrast,

the coverage of all the other business subjects is more than adequate.

The ideal source of information for the EIA for SMEs information base would involve a single

integrated, methodologically consistent source applying consistently to the entire SME sector.

Unfortunately, give the preceding analysis, this is not possible. Legal business subjects and

cooperatives are covered through the Annual Financial Returns submitted to FINA but that does

not apply to most crafts (approximately 5% of all crafts submits their financial report to FINA). Data

on crafts are dispersed between different institutions and registers and that makes it hard to collect

even the few existing variables from a single, reliable and consistent source of information.

The original source of information on crafts, MINPO’s Crafts Register, has IT limitations which inhibit

the ability to extract all the information that exists in the register. In addition, the Crafts Register

would need to be cross-referenced with other sources of information, such as Tax Office, REGOS and

HZMO, in order to increase its accuracy and usefulness. However, the methodologies applied by





36

these institutions are not consistent (e.g. see HZMO analysis). Due to these issues, even though it is

not an original / official source of information, HOKs “Book of Crafts” which is the most

comprehensive source of information on crafts (since HOK checks, cleans and systematises all

available information on crafts). Therefore, the Book of Crafts is the most comprehensive and

consistent source of information on crafts for the EIA for SMEs information base.

4.2 Recommendations

In line with the discussions, analyses and conclusions, the following recommendations are presented:

Variables for EIA for SMEs Information base

General information: key information to be included should focus on the SME sector at the

national level, with possible sub-division at the level of micro, small and medium sized

enterprises, cooperatives and crafts. This key information would include number of business

subjects and number of employees, their location (regional/county distribution) and their division

regarding NACE code;

Basic financial information: financial variables are reliable indicators of actual and potential

changes. MINPO is concerned about the likely magnitude of the financial impact of different

changes vs. the current situation. Consequently, it is important to track key financial variables

such as turnover, profit, investments in assets, expenditure on wages, expenditure on taxes,

profitability (profit per produced unit/service), productivity (such as number of produced

units/services per employee, per hour, per unit of raw material), etc. This list can be up-dated or

supplemented in line with specific needs;

In addition, the EIA for SMEs information base should incorporate scope for subdivisions such as:

- Legal type: the legislation recognises crafts as individual type of business with their own

specificity. The same thing can be said for legal entities that can be divided by different types of

business such as limited liability companies, simple limited liability companies, stock companies,

co-operatives as specific type legal type, etc. (for the full division of business subjects regarding

legal type see 3.1.1 Legal Framework and Box 1: Types of Business Subjects in Croatia);

- Size: in line with Croatian legislation, which is harmonised with the EU Small Business Act,

legal entities are sub-divided into micro, small and medium-sized enterprises. Due to major

differences between these groups (e.g. a micro enterprise can have one employee and a medium

size enterprise 249), it is necessary to have scope to sub-division of SMEs by size;

- NACE codes: division of enterprises by their main activities is useful information. Since it is

also aligned with Eurostat’s methodology, such information is particularly valuable due to

possibility of cross-referencing with EU countries;

- Regional /County distribution: this is also an important division, especially in a country know

to have a high degree of geographical heterogeneity. Regional (two regions) and county variations

(21 countries) can have a large influence on type of economic activities, duration

(seasonal/permanent), sector (services/manufacturing), etc.;

It is important to have the possibility to cross tabulate the above variables and sub-divisions.





37

These variables are available for all legal entities and cooperatives. As previously discussed, the

information available on crafts is much more restricted, but the following is available: total number,

number of employees and estimation of total income (due to issues explained in Box 3, this

information can be only considered as an estimate).

Data sources for EIA for SMEs Information base

It is evident from the preceding discussion that it is not possible to create an integrated information

base on all business subjects from a single source of information. The EIA for SMEs information base

will have to be merged from two different sources of information, namely:

FINA for all legal business entities, cooperatives and “large” crafts: covers 50% of business

entities, includes 156 different variables, considered as the most reliable source of information,

and scope for extensive sub-division and cross-tabulation. FINA charges for the data, but MINPO

already buys it every year for other purposes, so there is the potential to develop a time series

and extend the dataset in the future;

HOK for Crafts: although is neither an original nor an official source of information, it does

represent the most comprehensive source of information on crafts in Croatia. Other sources fail

to HOK’s Book of Crafts merge information on crafts into a single information base by cross-

referencing the relevant crafts information. Using the original/official sources of information

would require merging at least three different sources of information: MINPO’s Crafts register for

total number of crafts, Tax Office for information on income and HZMO for information on

number of employees. This would be a resource- and time-consuming task but one which HOK

has been doing for some time, has experience of, knows exactly which physical persons in Tax

Office are crafts and which are “regular” physical persons. It has an incentive to perform this task,

since its membership fees depend on the development of a comprehensive list of active crafts.

HOK’s Book of Crafts is thus the most useful source of information for the EIA for SME information

base.

Next steps

Two main activities are foreseen in completing this activity:

Creation of the EIA for SMEs information base based on the above recommendations;

Connection of the resulting EIA for SMEs information base with the proposed Virtual Centre of

Excellent on EIA for SMEs.





38

Annex 1: List of meeting for identification of data sources for EIA information base

Date Institution

25th May IAENL Project TAT

10th June MINPO, meeting with project manager and coordinator

19th June MINPO, Register of Supports to SMEs

19th June MINPO, Crafts Register

24th June DZS

24th June EIZ

24th June HSZ

26th June FINA

26th June HUP

28th June MINPO, Crafts Register

1st July DZS

4th July Register of Pension Payments

4th July CEPOR

5th July HGK

8th July Team meeting

11th July REGOS

12th July HOK

12th July HAMAG INVEST

30th August APIS IT Ltd





39

Annex 2: Paper on strengths and weaknesses of Croatian data sources produced by the

Improvement of Administrative Efficiency Project

Strengths and weaknesses of Croatian business statistics

The Croatian business statistics is generally strong with some weaknesses which if addressed could

make a good basis for sound political decision making as well as monitoring of efficiency of policies.

The biggest problem is that business statistics in not well coordinated, nor does it provides enough

information specifically on SMEs.

CBS and FINA are main sources

CBS as the provider of official business statistics has improved dramatically over the last years with

the introduction of the NACE rev. 2 in the Statistical Business Register and introduction of more

sources to make the data more reliable. SBS data are of very high quality and proves to be an

important input into the Statistical Business Register and the National Accounts. SBS data are quality

checked and edited in order to make sure they reflect the real economy. FINA is another invaluable

source of information on Croatian businesses. According the Accounting Act all limited liability

companies and crafts liable to pay enterprise tax are obliged to submit their detailed financial

accounts to FINA every year.

During the work on the SME Observatory Report as well as the National Strategy on SMEs, the

Improvement of Administrative Efficiency at National Level (IAENL) project team has worked with

time series of financial reporting from FINA covering the period 2008 to 2012 and data are very solid.

FINA data do have some setbacks; there is not 100% response and no statistical editing or imputation

of the companies that do not report. FINA do get back to companies that do not report or report

numbers that FINA finds unlikely but are not allowed to impute data unless the company officially

submits data. Basically that means that FINA cannot change a reporting or impute values based on

other information like NKD code and employment). FINA data only cover limited liability companies,

cooperatives, freelancers, and the crafts liable to pay enterprise taxes hereby omitting the bulk of

crafts, which is a major setback for analysis of the SME sector. Within the limitations of the data,

time series are smooth and gives possibilities of interesting analyses.

Altogether, there are good and reliable data on SME in Croatia. The main problem with the business

data in Croatia is that it is not 100% coordinated, sources sometimes diverge and some important

information are not available. This is the overall problem that needs to be addressed by increasing

cooperation as well as making sure that there are enough resources to implement the coordinated

data sources.

IAENL work with SME data

The IAENL team has together with the Ministry of Entrepreneurship and Crafts (MEC) organised a

series of meetings in the so-called Working Group of Statistical Analysis (WGSA). The purpose of the

group is to bring key stakeholders together to increase communication on the provision of business

data especially with respect to SMEs. Ultimately, the work of this group should bring about the

availability of better quality SME data. The WGSA consists of 19 persons from organisations (IAENL





40

Project, MEC, HAMAG INVEST, CBS, FINA, HGK, HOK, CEPOR, Economic Institute of Zagreb, and the

Ministry of Justice) and it has now met on a total of 6 occasions, the first of these meetings occurring

in November 2011. The meetings of the WGSA are chaired by the MEC, with the IAENL Project acting

as the Secretariat, mainly through the participation of Mr Klaus Pedersen, the Project's Key Expert for

Enterprise Statistics. Altogether, WGSA has facilitated communication.

Below follows a number of specific issues that IAENL project points out as crucial weaknesses that

needs to be addressed in order to make complete analysis tom the SME sector.

General capacity and IT resources

Lack of coordination and lack of timely updating of statistics can to some extent he explained by lack

of human resources in the primary sources as well as a lack of real demand for reliable business

statistics. Each producer of primary statistics is busy doing what they have to do and because there

are not enough resources, crucial development of quality improvements are not carried out. The lack

of sufficient resources can be tribute to the fact that there is not a strong demand for reliable and

timely enterprise statistics. The SME analysts and SW policy makers should make sure to the CBS and

FINA what their wishes are in order for CBS and FINA to prioritise SME data higher.

Coordination of efforts

The Working Group on Statistical Analysis (WGSA) has worked as a forum to discuss issues related to

SME statistics and to exchange information. If the WGSA is not continued, there will be no forum to

discuss these issues and to improve the quality of SME statistics,

Business demography

Business demography is about births and death of enterprises as well as information on how these

new enterprises are doing with respect to life expectancy, growth, employment etc. A part of

business demography is also to identify gazelles, rapid growing businesses. The easiest and most

cost-efficient way of compiling reliable business demography data is using the statistical business

register. The statistical business register in Croatia has a problem with inactive companies that have

not been reported closed or under liquidation. This makes analysis of enterprise closure and hence

business demography very difficult. Data from Ministry of Justice should be used to identify closures

and liquidations.

Inconsistencies between sources

Errors and omissions found in data sources are not always reported back to the primary source. As

well as information about closed and liquidated companies are not picked up by the statistical

business register.

Differences in activity codes (NKD) and size groups

There are differences in reporting of NKD codes between FINA and CBS. Companies report the official

NKD code whereas CBS use information from surveys (e.g. Industrial Production Survey) to update

information on NKD codes so they activity codes reflects the actual activities in the enterprise.

Crafts data are not aligned with other SME data





41

FINA data only includes the largest crafts eligible to pay company tax (in 2012 4,248 out of a total of

83,714). In general financial information on crafts is difficult to get hold of because financial

information on crafts are considered to be personal information due to the fact that crafts are

identical to physical persons. So far, the analysis of the SME sector has been split into separate

analyses of limited liability companies (legal persons) and crafts (physical persons). From a

macroeconomic point of view, it does not matter if a company is organised as a legal person or a

physical person, what matter, e, that value added, employment anti exports are created.

Furthermore, the identifier of a crafts (OIB number) is identical to the owners’ identifier. This creates

problems if a person has more than one craft or craft is sold to another person. The current law that

sets out the rules for OIB does not allow a craft to have a unique identifier.

Employment data in Crafts Register

MINPO keeps good record of crafts, in their administrative craft register. However, regular updates

with employment data from the Croatian Pension Fund (HZMO) would be a big improvement of the

register and make a valuable tool for analysis of employment in the crafts sector.

Import/export data

CBS who is the provider of official statistics on foreign trade does not provide import and exports

data on enterprise size groups. This is a major setback as foreign trade data on size groups are

essential to identify the strongest exporters. CBS has informed that together with the introduction of

the INTRASTAT system when Croatia becomes a member of the EU the foreign trade statistics will

subscribe to basic data from the statistical business register.

Employment data

Although some information on the labour force is available from CBS and from the FINA data,

detailed information on the qualifications on the labour force is needed for detailed analysis of

Research and Development (R&D) and Innovation. Data on level of education as well as job functions

would prove valuable in the analysis of levels of Research and Development and Innovation. Data on

labour force qualifications and job functions need to be combined with information on activity codes

(NKD) and size groups.

Data on outstanding payment

Illiquidity and (in-) solvency are major problems in the Croatian businesses. At the moment, there are

no systematic collections of data in this field. The lack of data makes it impossible to point at where

the problems are biggest and hence also to suggest solutions.

All together better coordination arid higher priority of SME data are required in order to improve the

grounds for transparent evidence based policymaking.





42

Annex 3: Type of data collected in the support register of measures and incentives for SMEs

(MINPO)





43





44





45





46





47





48





49





50





51





52





53





54





55





56





57

Annex 4: Type of data collected in the Crafts Register (MINPO)





58





59





60





61





62

Additional information registered by Crafts Register (numbers represent codes):

01 Registration of new craft and start of doing business

02 Registration of new craft without of start of doing business

03 Registration of the date when the crafts started doing business

04 Change of headquarters

06 Change of company name

07 Registration of separate facility

08 Termination of separate facility

09 Temporary suspension of craft

10 Termination of temporary suspension of craft

11 Check out of crafts

12 Temporary suspension and termination of temporary suspension within 30 days

13 Temporary suspension and termination of temporary suspension of separate facility

21 Registration of new activity

22 Termination of activity

23 Registration of seasonal craft

24 Change of period of performing seasonal craft or change from permanent to seasonal and

vice versa

25 Standby of craft (Article 37a)

26 Termination of standby of craft

31 Registration of expert staff

32 Change of expert staff

33 Check out (termination of working relationship) expert staff

41 Registration of manager of separate facility

42 Change of manager of separate facility

43 Registration of manager of craft

44 Registration of temporary manager

45 Registration of check out of temporary manager

46 Inheritance of craft

51 Termination of craft without professional employee

52 Termination of craft after one year

53 Termination of craft due to a protective measure that banns it from doing business

55 Termination of craft due to a decision of the Court of Honour

56 Termination of craft due to taking away its privilege

57 Termination of craft due to false documents

58 Termination of craft (Article 8. of the Crafts Act)

59 Termination of craft (Article 3. and 5. of the Crafts Act)

60 Termination of craft due to death

62 Termination of craft if the manager isn’t appointed

64 Termination of craft due to jail sentence

66 Termination of craft due to imposed security measure

67 Termination of craft due to not reporting suspension of craft for more than 30 days





63

68 Termination of craft due to absence of starting its work within 30 days after the expiration of

the temporary suspension

69 Termination of craft due to failure to comply with legal requirements (Article 14. of the Crafts

Act)

70 Termination of craft due to bankruptcy procedure

71 Accession of partners on the basis of a partnership contract (joint craft)

72 Withdrawal of partners on the basis of a partnership contract (joint craft)

84 Registration of connected craft on the basis of realized patent right

90 Other changes that are not mentioned.





64

Annex 5: Two most often requested HAMAG INVEST supports to SMEs – Request for guarantee (for

credit/loan) and Letter of intention





65





66





67





68





69





70

Annex 6: Type of data collected by HGK





71

Annex 7: Type of data collected by HOK





72

Annex 8: Type of data collected by HSZ





73





74

Annex 9 – Type of data collected by FINA





75





76





77





78





79





80





81





82





83





84





85

Annex 10 – Type of data collected by Tax Administration





86





87





88





89





90





91





92





93





94

Annex 11 – Type of data collected by REGOS





95

Improving Information to the Croatian Business Community … · 2017-01-12 · Organising study...

Documents

Transcript of Improving Information to the Croatian Business Community … · 2017-01-12 · Organising study...