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Lauded as the backbone of both the EU and the U.S. economies, Small and Medium-Sized Enterprises (SMEs) have dominated the heated debate over the Transatlantic Trade and Investment Partnership (TTIP) raging across Europe in 2015. TTIP negotiators are convinced that small businesses will be the main beneficiaries of the deal. However, due to varying levels of internalisation and innovation across sectors and countries, the benefits are unlikely to be evenly distributed. SMEs with cutting-edge technologies are the most likely to reap profits from TTIP, and thus spurring innovation should be among the priorities of especially the Central and Eastern European countries, which often lag in terms of pioneering products.
In 2013, the world's two biggest economies, namely the EU ($18.5 trillion) and the U.S. ($17.3 trillion), commenced negotiations on a free trade agreement aimed at reducing mutual barriers to trade, mainly in three areas: market access, trade regulation and broader rules of cooperation.1 According to research conducted by the Center for Economic and Policy Research (CEPR), arriving at the ambitious level of convergence would result in 0.5% and 0.4% GDP growth, respectively, for the EU and the U.S. The European Commission, which is the party negotiating the deal on behalf of all Member States, argues that the agreement is a remedy for the EU's sluggish recovery from the economic crisis and a strategy to counter rising competition from China and other BRIC countries. However, despite the promising predictions, the process of negotiations has proved anything but smooth, spurring unprecedented opposition from the public, with over 3 million Europeans signing the "Stop TTIP" petition2 and hundreds of thousands marching the streets of Berlin on October 2015 to protest the deal.3
The predominant argument forwarded by the opponents of TTIP is that the main beneficiaries of the agreement will be large multinationals, which will reap larger profits by having to comply with lower standards and exerting pressure on governments through the Investor State Dispute Settlement (ISDS) mechanism. The European Commission rebuts the argument about less stringent standards and promises to uphold all safety and environmental rules that citizens of the EU hold dear. Moreover, Cecilia Malmström, EU Trade Commissioner and the main architect of the deal, has recently put forward an idea to replace the highly controversial ISDS mechanism with an Investment Court System, designed to be a more transparent and predictable process for resolving conflicts between states and investors. The EC has also decided to focus on another line of argument, which is that TTIP will be designed to invigorate the backbone of the European Union's economy- Small and Medium-Sized Enterprises (SMEs).
The role of SMEs in Member State economies cannot be overlooked. It is estimated that as many as 99% of the EU's enterprises are micro, small or medium-sized firms.4 Although responsible for only one-third of the European Union's GDP, SMEs are the EU's biggest employers, providing jobs for over 88.8 billion people (66.8% of the EU's labour force).5 Nevertheless, relatively few companies occupying the economic "middle ground" decide to sell their products and services abroad. Estimates indicate that 42% of SMEs are engaged in some kind of internationalisation,6 but only onequarter sends their products across the border and even fewer, 13%, cater to third countries.7 Interestingly, the most frequent destination for products from European Union SMEs is the United States, with about a quarter (24%) of the SMEs exporting to third countries opting for the U.S.8 Other leading recipients include Switzerland, China, and Russia.9 Nevertheless, the major source of internationalised SMEs' turnover are operations in their own country (71%) and only one-tenth comes from third countries.10
Although few SMEs engage in extra-EU trade and even fewer export their products to the United States, it is worth looking at the role that these enterprises play in international and transatlantic trade. According to Eurostat's TEC data, SMEs account for as much as 32% of the total value of EU exports and 28% of the total value of the Union's exports to the United States.11 Of all EU firms engaged in trade, as many as 633,000 (80%) are small and medium-sized companies.12 When only exports to the United States is taken into account, the SME share rises to 88%.13 In sum, relatively few SMEs decide to engage in trade with third countries, however, for those who do, the United States is the paramount destination.
What is unaccounted for in statistical summaries is the indirect participation of SMEs in extra-EU trade through supply chains. If such effects are included, the share of SME exports to the United States would rise from 28% to 41%.14 Apart from supply chain gains, there are many effects that are difficult to measure and thus are omitted in the predictions. These include the gains of non-exporting SMEs that benefit from the rise of income and demand for products and services resulting from the increase in exports.
Even the most optimistic scenarios indicate that the general level of internationalisation of EU companies, SMEs in particular, leaves room for improvement. Nevertheless, international trade is something worth fighting for. Research shows that those who sell abroad enjoy unparalleled benefits. In their report, Mayer and Ottaviano call internationalised companies "the happy few" and argue that those firms not only are bigger and generate higher value-added contributions but also pay higher wages, employ more skilled workers and have higher productivity.15 These "superstars" are predominantly large companies, however, it remains unanswered whether their size is the effect or the cause of their international presence. Despite unfavourable odds, according to a report by the European Commission there is untapped potential in SMEs. More than 600,000 SMEs are already responsible for one-third of extra-EU exports. Considering that in the Member States there operate 21.2 million small and medium-sized firms, the potential for growth does seem to be robust.
What is the main reason behind SMEs' low level of internationalisation? Studies indicate that for many SMEs internal barriers are more important than external ones when exporting to other countries.16 Non-exporting firms often point to a lack of financing as a factor preventing their growth and international expansion. The situation worsened with the economic crisis, when SMEs became even less likely to obtain loans and tended to get offers at much less favourable rates than large companies.17 Although the situation is far from ideal, the European Central Bank has recently reported the first improvement since 2009 in the availability of bank loans for small and medium-sized companies.18 When it comes to firms involved in exports, external barriers of a bureaucratic nature rate highest on the list of obstacles to trade with countries outside the EU. This "red tape" involves compliance with rules, obtaining certificates, or providing onerous documentation.
Among firms exporting specifically to the United States, existing barriers are practically only bureaucratic since the average duties vary- with a few exceptions-at around 2%. Interestingly, red tape is the biggest hindrance regardless of the country or sector involved in exports across the Atlantic. According to a survey conducted by the European Commission in 2015, producers of food and beverages complain most about sanitary and phytosanitary measures (SPS) and labelling requirements.19 Firms in the chemical sector, as well as those in the textile industry, find the most burdensome technical barriers to trade (TBT) as well as conformity assessment, certification and inspections. Machinery producers would like to unify standards and conformity assessment procedures. Since compliance with those norms generates significant fixed costs, it is very difficult for small companies to be able to adhere to them. Unlike large multinationals, SMEs lack resources, both human and financial, to fulfil stringent requirements, which forces them not to limit their presence on the American market, but to forgo it altogether. TTIP, by introducing mutual recognition of standards, would significantly reduce the entry barriers for smaller enterprises. One of the examples of successful harmonisation of norms is the U.S.-EU Organic Equivalency Arrangement, which ensured that European organic products can be sold on the highly attractive American market without the need for additional certification.20
Recognising the barriers faced by SMEs when exporting to the U.S., as well as their primary importance to the EU economy, the EC decided to include in the transatlantic agreement a special chapter dedicated to them. It will be the first chapter of its kind ever included in a European Union trade agreement, although no concrete versions are yet available for the public. The textual proposal presented during the fifth negotiation round in May 2014 and made public on January 2015 boils down to providing SMEs with information and support regarding transatlantic market opportunities.21 It also predicts establishing a Committee on SME Issues, but does not provide further details on its specific tasks.
Many hope that the EC will go further with the provisions for SMEs. The European Economic and Social Committee (EESC) have proposed additional privileges, such as securing one seat on the TTIP Advisory Board for an SME representative, introducing a "think small principle" across the agreement, and creating a network of associations of European and American SMEs.22 Another interesting proposal is the introduction of preferential access to public procurement for SMEs. Such provisions already exist in the United States through the Small Business Act of 1953. In Europe, some Member States have introduced special access to procurement for smaller companies, e.g., by the end of 2015 in the United Kingdom, 25% of all government contracts are to be granted to British SMEs.23
Interestingly, the SME chapter in TTIP will not be the first of its kind for the United States, which already included it in the recently concluded Transpacific Trade Partnership (TPP). The recently released document reveals a very similar provision as that intended for TTIP. The Transpacific agreement's section on SMEs (Chapter 24) consists of only three short articles: Information Sharing, Committee on SMEs, and Non-Application of Dispute Settlement.24 The first two ensure that the states will provide SMEs with information about customs regulations and procedures, as well as establish a Small and Medium-Sized Enterprises Committee that will help SMEs with regards to exchanging best practices, supporting capacity-building, and organising seminars, workshops, and training. The third article rules out the possibility of using dispute settlement, also included in the deal, to enforce any of the provision included in the previous articles. The negotiations on the SME chapter in TPP ended as early as in 2012, which explains its rather superficial nature and might also indicate the level of ambition of the TTIP provisions for small businesses.
The innovative SME chapter aside, solutions designed specifically for SMEs have already been included in the EU's legislation. In 2008, the European Union adopted The Small Business Act (SBA), which listed among its priorities such provisions as promoting entrepreneurship, lessening the regulatory burden, providing access to finance and markets, and promoting internationalisation.25 The SBA was followed by Small Business, Big World (2011), which included special regulations aimed at alleviating the results of the global crisis. Support for SMEs was also incorporated into the Europe 2020 strategy, as well as the New EU Trade and Investment Strategy, announced by Trade Commissioner Cecilia Malmström on October 2015. Apart from legislation, with SMEs in mind the EU has also engaged in setting up platforms such as the EU SME Centre, IPR SME Helpdesks, TDI SME Helpdesk, Export Helpdesk, the Market Access Database and the Enterprise Europe Network. Moreover, there are many state-specific programmes aimed at exporters from particular sectors or to certain countries.
Despite the obvious abundance of measures designed for small and medium-sized enterprises, the success of the tools is difficult to assess. The study from 2011 shows that only one-third of internationally active SMEs is aware of the existing support programmes.26 From those who know about those programmes, only 26% take advantage of them, which makes up only 7% of all internationalised small businesses. The effectiveness of the measures can be based only on the participation rate, since for many initiatives evaluations are not conducted. There is no reason to believe that the provisions in TTIP will be more popular, considering that on average only 21% of SMEs are aware of the ongoing negotiations. In an online survey conducted by the European Commission, just 869 companies have taken part, of which 727 employed fewer than 250 people.27 Bearing in mind that in 2015 over 600,000 small businesses were engaged in international trade, both outcomes do not meet the expectations.
There are many reasons why SMEs might not want to participate in the dialogue about TTIP. Many European companies, especially micro firms operating locally, have no ambitions of entering foreign markets, and thus remain indifferent to the ongoing debate. Others might fear reputational damage due to the heated debate on the negotiations. Small businesses, unlike large firms, are usually represented by their owners, who may dread public ostracism after voicing an opinion about the highly controversial TTIP. Those who do speak up are associations uniting small businesses, although they are not unanimous in their opinions. The president of the Federation of Small Businesses (FSB) from the United Kingdom, David Caro, has lauded TTIP as "a land of opportunity for small business."28 The Association of German Chambers of Industry and Commerce (DIHK) and The German Association for Small and Medium-sized Businesses (BVMW) refrained from judging the agreement, but published position papers on the Investor-State Dispute Settlement mechanism, stressing their concerns about its impact on SMEs.29 Most of the negative views have been voiced by the Small and Medium-sized Enterprises from Austria (KMU), which argues that "SMEs would suffer massively due to the radical opening of the domestic market to multinational corporations."30
Unlike small and medium companies, large firms, especially multinationals, are well informed about the deal. Large companies face the same external barriers as SMEs and for them an ambitious TTIP translates into considerable savings and new opportunities. The presence of multinationals is especially visible in their lobbying efforts. According to the official data released by the EC, the top three lobbyists on TTIP are the Trans-Atlantic Business Council, EUROCHAMBRES (the Association of European Chambers of Commerce and Industry), and European Round Table of Industrialists.31 However, these numbers are based only on meetings with top EU officials, who, since December 2014, have been obliged by the Commission president, Jean-Claude Juncker, to register their meetings with lobbying parties. It is an open secret that, instead of high officials, lobbyists target the TTIP negotiation teams, thus the idea forwarded by European Ombudsman Emily O'Reilly to extend the obligation of registering meetings to TTIP negotiators seems justified and needed.32
Another issue raising concerns is the problem of former commissioners and senior EC officials leaving for private sector jobs, predominantly multinationals. The Corporate Europe Observatory (CEO) has estimated that the "revolving door" problem involves nine out of 26 of the previous term commissioners.33 Among them is Karel De Gucht, former trade commissioner and initiator of TTIP, who is now a member of the board of Proximus (a telecommunications company) and a collaborator with CVC Capital Partners (an investment company).34 Each commissioner and top-level EC official is prohibited from lobbying for private sector companies for up to 18 months after they leave office, but in the case of lengthy negotiated trade agreements, this period does not seem to be sufficient.
Although the recent financial crisis has strengthened protectionist sentiments, not all SMEs fear large companies. Many find the interests of big firms congruent with their own agendas, because fewer barriers to trade generally also benefit small business. Others depend on large companies through supply chains. Thanks to the single market, SMEs are also much better prepared for competing with foreign companies. When asked about their concerns about exports to the U.S., many considered regulatory barriers worse than competition.35 The bulk of successful or aspiring exporters to the United States manufacture niche or innovative products. Unlike large companies, small businesses are able to quickly adjust to the changing needs of consumers. It is exactly the SMEs that innovate that can reap the profits of the transatlantic free agreement.
However, providing SMEs with information promised in the SME chapter is not sufficient for them to take full advantage of the deal. Since innovation is a crucial component of the success of many SMEs, provisions regarding Intellectual Property Rights (IPRs) are of paramount importance. In 2013, according to the European Patent Office, 29% of all patents were registered by SMEs or individual inventors.36 Nevertheless, obtaining and defending IPRs remains time-intensive and costly, which forces many SMEs to opt for different solutions, such as trade secrets, confidentiality agreements and marketing advantages. These, however, do not guarantee the same level of protection, thus it is crucial to provide support and information about IPR protection and enforcement in the United States. A good example of a successful platform helping SMEs with intellectual property rights is the China IPR SME Helpdesk.
Another untapped potential is the presence of European SMEs online. One of the simplest solutions to facilitate SMEs that want to sell their products abroad is raising the value of packages exempt from tax and duty. Although the U.S. is the most popular destination for EU SMEs shipping outside Europe, only parcels worth less than $200 do not require additional payments.37 Raising that threshold could encourage SMEs to ship their products to the U.S. in the short run, and to start further international expansion in the long run. Similarly, many exporting SMEs are engaged in selling digital products, which include software, music, videos, and e-books. At present, exporters of digital products to the United States are required to pay duties. There is strong pressure from the EU for duty-free treatment of digital products, for example, placing the creation of the Digital Single Market among the top 10 priorities of President Juncker's commission. As of 2016, all digital products are to be free of all intra-EU regulatory barriers.38
In 2014, 10 countries, including Poland, celebrated 10 years of membership in the European Union. Despite the achievement of enormous development in a decade by all of the new EU economies, SMEs in particular lag in matching Western European levels of turnover and internationalisation. SMEs from Germany, France, United Kingdom, Italy, and Spain that export to the United States comprise as much as 75% of all small European businesses trading with the U.S.39 Also, although in general the United States is the most popular destination for EU small and medium-sized enterprises, after disaggregating the data it remains the top destination only for the United Kingdom, Belgium, and Italy.40 For French and German SMEs, the U.S. is the second biggest market after Canada, while Central and Eastern European SMEs tend to trade much more with China and Russia.41 Those latter countries are the top extra-EU export destinations for Polish SMEs.42 Those numbers are also reflected in the participation rate in the EC survey regarding barriers to trade with the U.S. The highest number of responses came from Germany (196), France (118), Spain (75), Italy (72), and the UK (69).43 Also, SMEs in Eastern Europe often lack representation, since the biggest small business associations, such as the Federation of Small Businesses (FSB), the French Small and Medium-Sized Employers Organisation (CGPME), and the Association of German Chambers of Industry and Commerce (DIHK), are located in the UK, France, and Germany, respectively.
The lower level of productivity, fewer trade relations with the U.S., and the lack of representation place SMEs from Central and Eastern European countries among the unlikely beneficiaries of TTIP. However, even if they themselves will not engage in trade with the U.S., they might reap benefits thanks to the concurrent effects of the deal. The majority of the new Member States export their products to the single market, often providing semi-finished goods within supply chains. Thus, increased exports by firms buying their products might contribute to higher profits for SMEs. Similarly, small businesses from less-developed European countries can benefit from the substitution effect of trade. Economies such as Germany, France, or UK are likely to increase their production of goods in sectors in which they have a competitive advantage against the U.S. (e.g., machinery) at the expense of less-competitive sectors (e.g., agriculture and food production).44 Companies, including SMEs, from new EU member countries could fill in that void and increase their exports and profits. Undoubtedly, some firms from less-competitive sectors will prove inefficient in the face of dropping prices and will be forced out of the market.
Being the biggest country to join the European Union after 2004, Poland has one of the lowest levels of exports among its SMEs. Polish small and medium-sized companies tend to heavily rely on the considerable internal market, which has helped Poland remain a "green island" amidst the turmoil of financial crisis of 2008 and 2009. However, in a time of recovery, the low level of internationalisation translates into sluggish economic growth and hinders development. Only as few as 2.8% of Polish SMEs export their products to other EU countries and only 1.6% engage in extra-EU exports.45 Only 25% of specialised exporters among small businesses sell their products abroad.46 SMEs in Poland are also marred by low productivity, contributing only half of the value-added contribution to the Polish economy.47 This proves that both firms and government should prioritise combating the shortage of skills and innovation. Although entrepreneurs still often mention bureaucratic burdens as a barrier, the amount of red tape is steadily decreasing in Poland.48
The vision of a large increase in Polish exports thanks to the Transatlantic Trade and Investment Partnership does not seem very probable, nevertheless, even small Polish businesses can gain certain benefits thanks to the signing of the agreement. Many SMEs in Poland are part of the supply chains of German companies exporting to the United States. Germany is predicted to be one of the biggest beneficiaries of the deal because it already has the largest value of exports to the U.S. and its business associations have great capacity. Polish firms exporting to Germany can expect positive spillover effects in the form of increased demand for their products. What is more, Polish SMEs involved in the food and beverage sector can reap benefits due to the outflow of capital from those sectors in Western Europe. Moreover, although not many Polish SMEs are engaged in exports, they are characterised by optimism, with 28% of respondents considering it likely that they will start exporting for the first time within the next 12 months.49 Polish entrepreneurs also proved better informed about the ongoing TTIP negotiations, with 27% of SMEs declaring an awareness of the process (compared to the EU average of 21%).50 Nevertheless, Polish interest in TTIP does not focus on opportunities for small businesses, but rather on the geopolitical benefits that the agreement could bring about, especially thanks to easier access to American sources of energy, which is also of great importance for the competitiveness of Poland's chemical sector.
In order for the TTIP negotiations to succeed and receive approval from European citizens the European Commission must strengthen its efforts towards rebuilding trust for its negotiating mandate. The initial negligent approach of the EC towards providing information about the agreement to the public resulted in the proliferation of myths and half-truths, thus it is of pivotal importance that the process of increasing the transparency of TTIP is continued. This should involve more regulations and information regarding meetings with lobbyists and the revolving door scenario for top EU officials. Moreover, the EC should strive to include more ambitious provisions for SMEs than those present in TPP, especially about access to public procurement and IPR protection. TTIP can prove very beneficial for many innovative SMEs, including those involved in the market of digital products, and hence the initiative of duty-free treatment of such products must be upheld. Fostering innovation should also be a key ambition of the new Member States, whose SMEs often lag in terms of cutting-edge technologies. Among them is Poland, which ought to assign public funds for programmes aimed at incentivising entrepreneurs to invest in skills and innovation, while also making sure that these initiatives are properly targeted and evaluated. Last, SMEs must more actively participate in the TTIP debate, because only a unified stance can ensure that the agreement is best suited to their needs.
1 The International Monetary Fund , 2015, www.imf.org.
2 "Three million people unite to derail TTIP," EurActive, 6 October 2015, www.euractiv.com.
3 "The TTIP of the spear," The Economist , 17 October 2015, www.economist.com.
4 The category of micro, small and medium-sized enterprises (SMEs) is composed of enterprises that employ fewer than 250 people and which have an annual turnover not exceeding euro50 million and/or an annual balance sheet total not exceeding euro43 million. Within the SME category, a "small enterprise" is defined as an enterprise that employs 10-50 people and whose annual turnover and/or annual balance sheet total does not exceed euro10 million. Within the SME category, a "microenterprise" is defined as an enterprise that employs fewer than 10 people and whose annual turnover and/or annual balance sheet total does not exceed euro2 million. Source: The Commission Recommendation of 6 May 2003 (2003/361/EC) concerning the definition of micro, small and medium-sized enterprises.
5 P. Muller et al ., "Annual Report on European SMEs 2013/2014-A Partial and Fragile Recovery," Directorate-General for Enterprise and Industry, European Commission, July 2014.
6 These involve: export, import, technical cooperation, being subcontractor, having subcontractor, FDI.
7 "Opportunities for the Internationalisation of European SMEs," Enterprise and Industry, European Commission, 2011.
8 "European SME Exporting Insights," UPS, September 2014.
9 Ibidem.
10 "Opportunities for the Internationalisation of European SMEs," op. cit.
11 "Small and Medium Sized Enterprises and the Transatlantic Trade and Investment Partnership," European Commission, 2015.
12 Ibidem.
13 Ibidem.
14 Ibidem.
15 T. Mayer, G. Ottaviano, "The Happy Few: The Internationalisation of European Firms," Bruegel Blueprint Series, Vol. III, November 2008.
16 B. Fliess, C. Busquets, "The Role of Trade Barriers in SME Internationalisation," OECD Trade Policy Papers, 1 December 2006.
17 O. Kaya, "SME financing in the euro area," EU Monitor, Deutsche Bank Research, 14 October 2014.
18 "Report on the results of the Survey on the Access to Finance of Enterprises in the euro area-October 2014 to March 2015," European Central Bank, 2 June 2015, www.ecb.europa.eu.
19 "Small and Medium Sized Enterprises and the Transatlantic Trade and Investment Partnership," op. cit.
20 "US-EU Organic Equivalency Arrangement," United States Department of Agriculture, 3 August 2015, www.usda-eu.org.
21 "Textual Proposal Small And Medium-Sized Enterprises," 7 January 2015, www.trade.ec.europa.eu.
22 E. Butaud-Stubbs, "TTIP and its impact on SMEs," European Economic and Social Committee, 2 July 2015.
23 "2010 to 2015 government policy: government buying," Crown Commercial Service, 8 May 2015, www.gov.uk.
24 "Text of the Trans-Pacific Partnership," New Zealand Ministry of Foreign Affairs and Trade, November 2015, www.tpp.mfat.govt.nz/text.
25 "'Think Small First: A 'Small Business Act' for Europe," The Commission of the European Communities, 25 June 2008, p. 4.
26 "Opportunities for the Internationalisation of European SMEs," op. cit.
27 "Small and Medium Sized Enterprises and the Transatlantic Trade and Investment Partnership," op. cit.
28 D. Caro, "TTIP is a land of opportunity for small businesses," EurActiv, 19 June 2014, www.euractiv.com.
29 "Deutscher Industrie- und Handelskammertag," DIHK, 11 July 2014, www.dihk.de.
30 "A Call for Resistance!," KMU gegen TTIP, 2015, www.kmu-gegen-ttip.at.
31 J. Panichi, "The Commission's corporate job pipeline," Politico, 28 October 2015, www.politico.eu.
32 Ibidem.
33 "The revolving doors spin again," Corporate Europe Observatory, 28 October 2015, www.corporateeurope.org.
34 Ibidem.
35 "European SME Exporting Insights," op. cit.
36 "Patent filings at the European Patent Office reach all-time high," European Patent Office, 6 March 2014, www.epo.org.
37 "European SME Exporting Insights," op. cit.
38 "Digital Single Market- Bringing down barriers to unlock online opportunities," European Commission, 2015, http://ec.europa.eu.
39 Author's calculations based on: "Small and Medium Sized Enterprises and the Transatlantic Trade and Investment Partnership," op. cit.; L. Cernat, A. Norman-López, A. Duch T-Figueras, "SMEs Are More Important than You Think!-Challenges and Opportunities for EU Exporting SMEs," Chief Economist Notes, iss. 3, September 2014.
40 "European SME Exporting Insights," op. cit.
41 Ibidem.
42 Ibidem.
43 "Small and Medium Sized Enterprises and the Transatlantic Trade and Investment Partnership," op. cit.
44 J. Hagemejer, "Liberalization of trade flows under TTIP from a small country perspective: The case of Poland," WNE WP, no. 17, 2015.
45 T. Kosciolek, "Eksport polskich MMSP poza UE," 5 November 2014, www.internacjonalizacja.pl.
46 Ibidem.
47 "2014 SBA Factsheet Poland," DG Enterprise and Industry, European Commission, 2014.
48 The World Bank Doing Business named Poland the biggest improver in terms of administrative burden between 2012 and 2013.
49 "European SME Exporting Insights," op. cit.
50 Ibidem.
Copyright Polish Institute of International Affairs 2015