The President of the CEC and the ACCI Mr. Konstantinos Michalos, σε συνέχεια της κατάθεσης του σχεδίου για το νέο αναπτυξιακό νόμο στη Βουλή, απέστειλε στον υπουργό Οικονομίας, Ανάπτυξης και Τουρισμού κ. George Stathakis letter pointing out that unfortunately it was found that the proposals submitted by the chamber community, in the context of the consultation of the new Development Law, have not been taken into account.

However, as reported by Mr. Michalos For the implementation of the new development law, dozens of decrees, regulatory acts and ministerial decisions are required, which can modify the draft law in the right directions and proceed immediately with its activation.

Michalos' letter on the Development Law - Content

"Reading the draft law entitled "Institutional framework for the establishment of Private Investment Aid schemes for the regional and economic development of the country – Establishment of a Development Council and other provisions", we noted with regret that the proposals we had put forward in the context of the consultation of the new Development Law have not been taken into account.

particularly:

• Not only is the loss of 30% of the aid rate to which the investment vehicle is entitled for projects which do not fall under specific categories of aid maintained, but the possibility of receiving 100% of the grant rate in the Independent SMEs scheme, subject to conditions, is abolished. It should be noted that this possibility existed in the draft law that had been put to consultation.
• Under the proposed provisions, an existing small and medium-sized enterprise which does not belong to a specific category of aid cannot be supported by the subsidy scheme. The criminalisation of affiliated enterprises also continues to exist in the draft law, as an investment vehicle cannot receive a subsidy if it has affiliated companies and does not belong to a special category of investment project. We again propose the abolition of this provision and the financing of all SMEs also with the subsidy scheme, without any additional conditions.
• The concept of the New Independent Media has been further tightened, even interfering with the criteria and definitions adopted by the EU regarding the size of enterprises. It is, to say the least, incomprehensible for the Greek Government to formulate stricter rules and conditions than those laid down by Community legislation.
• The transitional provisions included in the draft law – which had not been put to consultation – abolish the advance payments provided for in the previous Development Laws. In the new Development Law, instead of setting an advance payment rate, the method of payment of approved aid in the previous laws is changed. Thus, aid beneficiaries will have to wait seven years to receive their grant. This regulation creates huge problems for the market, even jeopardising the survival of the companies that had granted the subsidy. Moreover, by nullifying any notion of continuity and credibility of the state, it further degrades the attractiveness of the country as an investment destination. For these reasons, this provision, which is found in Article 77 of the draft law, should be repealed.
• The profit clause for the 6 years of the existing operation of the companies, as a condition for the possibility of receiving a grant, is not only maintained but with the draft law the 6-year period is increased to 7 years. We call on you, even now, to abolish it, repeating the alternative proposal to reward profitable businesses through the rating system for investment projects.
• In spite of our proposals, article 11 still excludes aid to large companies in any category. A negative provision, mainly for Tourism, is maintained, which prohibits the support of Large Enterprises that wish to proceed with the modernization of an integrated form in the Regions of Western Macedonia, the Ionian Islands, Crete, Central Greece, Attica and the South Aegean. In this way, a huge percentage of the country's hotel capacity becomes ineligible for funding and important hotel facilities are at risk of obsolescence. Especially for the South Aegean region, which is also receiving a huge wave of refugee flows, this development is expected to have a particularly negative impact. We would point out that, although a specific category of aid has been provided for in Article 12, it is not clear whether it includes large enterprises.
• The provision for congested areas, instead of being abolished, as we had proposed, remains in paragraph 4(ih) of Article 7, excluding tourist areas from the possibility of aid. We call on you again to withdraw this provision.
• The exclusion of all investment projects in the Energy sector, including investment projects in the field of RES, from the inclusion in the framework of the New Development Law is maintained. Investment projects for heat generation and small hydroelectric parks are exceptionally supported. We continue to support and call for the scope of eligibility of investment projects to be broadened in the energy sector, which is crucial for development, to include projects for all forms of renewable energy production.
• The determination of the ECU 20 million as an additional limitation for investment projects and their categorisation as Major Investment Projects, it is again a National Initiative, as well as the limitation of aid to EUR 5 million. euro per investment project. During the consultation process on the text of the draft law, we highlighted the problems that these provisions will create. During the consultation process on the text of the draft law, we highlighted the problems that these provisions will create. It is inconceivable that such a provision should be retained in the final draft law, as there is no company wishing to implement an investment project of more than EUR 20 million. euro, with the aim of keeping the tax rate at the levels you have currently set. We propose that this provision be abolished and that the EUR 50 million limit be maintained. euro as limits for large investment projects. We believe that even now, after the conclusion of the consultation and the tabling of the draft law, the cumulation limits of EUR 10 million and EUR 20 million should also be reviewed. euro for individual and linked enterprises respectively as a total of aid.
• Article 76 of the draft law also defines the deadlines for the completion of the investment plans of Law 3299/04 and Law 3908/2011. On 2-6-2016, a draft law is submitted in which a deadline of 6 months is set for the implementation of 50% of a project, so that an additional extension can be granted until 30-6-2018. This deadline is unrealistic. It is not feasible for a company to implement in 6 months 50% of the approved budget of its decision to join, under the conditions currently prevailing in the market: with tax obligations constantly increasing, transactions still limited by capital controls and financial institutions refusing funding, not only for investments, but also for the current daily needs of the business. For this reason, we again request the amendment of this provision and the setting of the completion date as 31-12-2017 without the obligation to implement the 50% by 31-12-2015 or 31-12-2016 that you have foreseen.
• Finally, it is with regret that we note from reading the accompanying Impact Assessment Report that the part of the National Public Investment Programme for the next six years for the entire Greek territory will amount to EUR 80 million. euro. This amount is hopelessly small, at a time when the Greek economy is in dire need of investment and jobs. The financing of Greek businesses, through the country's main development tool, amounts to essentially a little more than 10 million euros per year, when the annual investment costs of a multinational company are at least ten times higher. The chamber community responded immediately and with specific proposals to your invitation for consultation, recognizing the crucial importance for the Development Law in the effort for the recovery of the Greek economy. Unfortunately, we find that our proposals have fallen on deaf ears. The business world, instead of being encouraged and supported, continues to be punished and deterred from making investments, through successive restrictions and exceptions. With the current proposed provisions, the new Development Law that businesses have been waiting for with anxiety and patience, causes disappointment and despair.

Once again, we point out that the goal of growth cannot be achieved without viable Greek businesses. It cannot be achieved without a stable and favourable business environment, with fewer obstacles and more incentives to take investment initiatives.
We therefore ask for your actions, so that the draft law is amended – even now – in the right directions and that its activation proceeds immediately."