Federal Budget Submission to the Australian Government FEBRUARY Page 1

Transcription

1 Federal Budget Submission to the Australian Government FEBRUARY 2016 Page 1

2 RESTAURANT & CATERING AUSTRALIA Restaurant & Catering Australia (R&CA) is the national industry association representing the interests of 35,000 restaurants, cafes and catering businesses across Australia. R&CA delivers tangible outcomes to small businesses within the hospitality industry by influencing the policy decisions and regulations that impact the sector s operating environment. R&CA is committed to ensuring the industry is recognised as one of excellence, professionalism, profitability and sustainability. This includes advocating the broader social and economic contribution of the sector to industry and government stakeholders, as well as highlighting the value of the restaurant experience to the public. Cover page: Top left and bottom middle images courtesy of Tourism Australia Page 2

3 Table of Contents EXECUTIVE SUMMARY 4 RECOMMENDATIONS 5 THE VALUE OF AUSTRALIA S VISITOR ECONOMY 6 Industry Snapshot: café, restaurant & catering sector 7 Tourism employment 7 At a glance: trends in the hospitality sector 9 BUDGET INITIATIVES 10 TREASURY 10 Goods and Services Tax 10 Fringe Benefit Tax 12 Superannuation and Working Holiday Makers 14 Superannuation Guarantee 14 FOREIGN AFFAIRS & TRADE 15 Tourism Australia 15 EMPLOYMENT 16 Registered organisations 16 IMMIGRATION 17 Immigration outreach officers 17 Administration of the industry training fund 17 EDUCATION 19 Tax deductions for training 19 HEALTH 20 Food Safety 20 Page 3

4 EXECUTIVE SUMMARY Australia s visitor economy is a $113 billion industry, employing close to one million people and supporting 267,000 businesses across metropolitan and regional Australia. The restaurant, café, and catering sector is the largest contributor to the visitor economy; employing 554,200 people across 35,900 businesses. These businesses are small businesses; with 93 per cent of these organisations employing 19 people or less. Tourism has been identified as one of Australia s five super growth industries second only to gas with the sector expected to grow more than 10 per cent faster than global gross domestic product. Australia s top five super growth industries including tourism have the potential to deliver an additional $250 billion to the national economy over the next 20 years if these growth projections are realised. As Australia moves towards a service-based economy as a result of globalization and growth in Asian source markets, the importance of the tourism and hospitality industry will become even more prevalent. Employment growth in the hospitality industry is expected to be higher than any other sector; growing at 16.9 per cent or 93,600 jobs. The Australian Government has also adopted an ambitious target of doubling overnight visitor expenditure to $140 billion by Ensuring policy settings support the visitor economy will be necessary to achieve growth targets and improve productivity and employment opportunities in the Australian economy. As the peak industry association representing the largest employer in the visitor economy, Restaurant & Catering Australia (R&CA) advocates for a range of measures that improve the productivity of small hospitality businesses across Australia. Examining the application of the GST across fresh food and produce to simplify the calculation of GST credits, as well as the treatment of superannuation for Working Holiday Makers will significantly reduce red tape and administrative burden for operators. Further, the Superannuation Guarantee under the Restaurant Industry Award must be increased to $600 per month to match historical wage growth. Finally, funding for Tourism Australia must be maintained in the budget to continue to build on campaigns already in market and promote Australia as a holiday destination. Commitment to these recommendations will ensure the sector continues to make a vital contribution to the Australian economy. Page 4

5 RECOMMENDATIONS TREASURY GOODS & SERVICES TAX R&CA supports in principle the broadening of the GST to include fresh food and produce to allow for the removal or abolition of less efficient taxes, while reducing the compliance burden on hospitality operators in determining GST credits in their business. FRINGE BENEFIT TAX Small businesses with an annual turnover less than $2 million should be exempt from paying FBT entirely under the Small Business Entity concessions. SUPERANNUNATION Remove the requirement to pay superannuation to overseas workers including Working Holiday Makers. Superannuation that is not claimed or collected by the Australian Government should be contributed to an education training fund. Raise the Superannuation Guarantee Threshold to $600 per month ($1800 per quarter) and index to CPI. FOREIGN AFFAIRS & TRADE TOURISM AUSTRALIA Maintain funding for Tourism Australia and initiatives that promote Australian food and wine experiences to international visitors. EMPLOYMENT REGISTERED ORGANISATIONS Adequately fund education programs for registered organisations on their new legislative obligations to ensure compliance and greater accountability. IMMIGRATION OUTREACH OFFICERS & INDUSTRY TRAINING FUND Reinstate the Outreach Officer Program in the budget. Revise proposed structure of Industry Training Fund contributions and work with industry-based RTOs to appropriately fund skill sets required by the sector. EDUCATION TAX DEDUCTIONS FOR TRAINING Grant employers a 120% tax deduction for expenditure on training and development. HEALTH FOOD SAFETY INITIATIVES Resource a best-practice food safety management campaign including mandatory training for food handlers nation-wide. Page 5

6 THE VALUE OF AUSTRALIA S VISITOR ECONOMY Deloitte s Positioning for Prosperity? Catching the next wave report identifies tourism as one of Australia s five super growth industries, with the sector expected to grow more than 10 per cent faster than global gross domestic product (See Figure 1). Australia s top five super growth industries including tourism have the potential to deliver an additional $250 billion to the national economy over the next 20 years if these growth projections are realised 1. The café, restaurant and catering sector is the largest contributor to Australia s tourism industry; employing 554,200 Australians across 35,900 businesses. The sector generates $24.3 billion in turnover, of which $15.6 billion is attributed to national Gross Value Added (GVA) and $4.4 billion to tourism GVA. Ensuring this sector continues to prosper is essential for the growth of the broader economy. Figure 1: Projected annual global industry output growth, Gas Tourism Agribusiness Health International education Wealth Management Water and waste services Retail and wholesale Other education and training Public administration Transport and logistics Business and property services Telecommunications Oil Banking Mining Construction ICT Manufacturing Media % GGDP GGDP - 10% GGDP Global growth rate (%) 1 Deloitte (2013) Positioning for Prosperity? Catching the next wave Source: Deloitte Access Economics Page 6

7 Industry Snapshot: café, restaurant & catering sector THE SECTOR CONTRIBUTES $24.3 BILLION TO THE NATIONAL ECONOMY $24.3 Billion TAKEAWAY COMPONENT, $16.4 BILLION CONTRIBUTES $15.6 BILLION TO NATIONAL GROSS VALUE ADDED AND $4.4 BILLION DIRECTLY TO THE TOURISM INDUSTRY THE SECTOR EMPLOYS 554,200 PEOPLE WITH THIS NUMBER EXPECTED TO INCREASE TO 647,900 BY 2019 EMPLOYMENT GROWTH 35,911 PROJECTED AT 16.9% OR 93,600 JOBS BY CAFÉ, RESTAURANT, & CATERING BUSINESSES IN AUSTRALIA 93.1% ARE SMALL BUSINESSES THIS RATE OF GROWTH IS HIGHER THAN ANY OTHER SECTOR IN THE AUSTRALIAN ECONOMY Page 7

8 Tourism employment The hospitality industry is the single largest employer across all tourism-related sectors of the visitor economy. Service Skills Australia s Tourism, Travel and Hospitality Environmental Scan 2014 highlights that strong domestic demand and a growing tourism base is expected to lead to phenomenal employment growth in the visitor economy over the next five years, particularly in the café, restaurant and takeaway food sector 2. Over the five years to August 2013, almost all employment growth in the hospitality industry was led by the café, restaurant and takeaway food services sector, with a growth rate of 15.1 per cent or 69,400 jobs (see Figure 2) 3. The growth in the sector was largely being driven by higher disposable incomes and an increase in time poor households. Over the same period, other hospitality sectors including accommodation and clubs actually experienced negative growth in employment. Figure 2: Employment growth over the five years to August 2013, by sector ( 000s) -4.0 Accommodation -1.9 Clubs (Hospitality) 7.2 Pubs, Taverns and Bars 69.4 Café, Restaurants and Takeaway Food Services Further, projections released by the Department of Employment indicate growth in café, restaurant and takeaway employment is expected to rise even further, with an increase of 16.9 per cent or 93,600 workers required by November Policy settings must support the fastest growing sectors of the tourism industry including hospitality, and recognise the employment potential of this sector if we are to grow the national economy and realise our Tourism 2020 growth targets. 2 Service Skills Australia (2013) Tourism, Travel and Hospitality Environmental Scan 2014, p.21 updated with figures from the Department of Employment (2014) 2014 Employment Projections, Industry projections to November Department of Employment (2013) Employment Outlook for Accommodation and Food Services, December DEEWR (2012) Employment Outlook to 2017, p.3-4 Page 8

9 Trends in the hospitality sector The hospitality industry is a complex and dynamic sector, often providing a barometer for consumer sentiment and economic activity. While improvements in consumer sentiment has led to an increase in industry turnover to $24.3 billion, restaurant yield continues to decline with spend per person falling from $33.5 to $32.8 per person 5. R&CA s 2015 Industry Benchmarking Report found an improvement in business sentiment around sales and profitability, while subdued sentiment around employee numbers, menu and meal prices, and capital expenditure. Half of businesses indicated they believed sales would increase over the next 12 months compared to only 35.6 per cent last year. Further, 39.0 per cent of business believe profitability would increase, compared to 26.7 per cent of businesses in However, staff wages and on-costs continue to be the largest expense in restaurant businesses, accounting for up to 42.2 per cent of business costs, often making trading on weekends and public holidays unviable. In an attempt to bring labour costs down, staff hours are reduced in favour of the business owner working weekends and value-add food services such as ready-to-use ingredients (peeled and diced onions for example). In addition, shortages in labour including waiters, chefs, and restaurant managers has resulted in an increasing reliance on temporary skilled workers, where the process for applying for visas is burdensome and difficult to navigate. Apprentice numbers also continue to dwindle, making existing shortages even more prevalent. The growing popularity of shows such as MasterChef and My Kitchen Rules continue to build momentum and demand for restaurant and café experiences, while mobile food vendors, small bars, and food festivals have changed the operating environment of many food operators. Food and wine experiences are an increasingly important component of our selling proposition to international visitors, with research indicating Australia ranks second only to France for food and wine experiences among people who have visited the country 6. The sector continues to balance local and international demand for culinary experiences with an operating environment that is filled with complexity, regulation, and escalating operating costs. 5 Food Industry Foresight (2015) Dining Out Data, May Tourism Australia (2013) Gourmet Tourism is Growing Page 9

10 BUDGET INITIATIVES TREASURY Goods and Services Tax Since the delivery of the Federal budget, discussions have arisen over an increase to and broadening of the Goods and Services Tax (GST) to include fresh food and produce. The Re:Think Tax Discussion Paper rightly identified that restaurants, cafes and caterers face considerable complexity in determining and claiming GST credits, as GST only applies to a proportion of their inputs. For example, there is no GST on raw chicken, however GST is applicable to value-add products such as smoked chicken, cooked chicken or diced chicken products. This means to determine their GST liability, restaurant owners are forced to work through invoice by invoice the GST paid, while small businesses in other sectors can simply assume that all their inputs attract GST. For a restaurant or catering business, the process of claiming a credit for the GST component of the purchase price of the item is varied and complex. The broadening of the tax base to include fresh food and produce for this sector could represent savings to businesses by reducing red tape and the administrative burden associated with calculating GST paid for tax purposes. While this has been addressed to some extent by the averaging method made available by the ATO, greater simplification of the GST would remove the additional burden altogether. Analysis conducted by KPMG over page reveals the economic impact of changes to the GST, and the implications for smaller inefficient taxes such as conveyancing duty, insurance tax and payroll tax should the GST be increased or broadened 7. 7 KPMG (2011) CPA Australia: Economic Analysis of the Impacts of Using GST to Reform Taxes, September 2011 Page 10

11 Scenario Revenue Generation Impact on living standards Impact on inefficient taxes 12.5% GST replacing some less efficient taxes $10.5 billion in additional revenue $1.6 billion higher Abolition of: Insurance duty and fire insurance duty Motor vehicle taxes stamp duty and registration 10% of commercial conveyancing duty 15% GST replacing some less efficient taxes $20 billion in additional revenue $4.7 billion higher Abolition of: Insurance duty and fire insurance duty Motor vehicle taxes stamp duty and registration commercial conveyancing duty 40% of payroll tax 20% GST replacing some less efficient taxes $40 billion in additional revenue $4.6 billion higher Abolition of: Insurance duty and fire insurance duty Motor vehicle taxes stamp duty and registration commercial conveyancing duty all of payroll tax Uniform GST replacing some less efficient taxes $11.5 billion in additional revenue $4.0 billion higher Abolition of: Insurance duty and fire insurance duty Motor vehicle taxes stamp duty and registration Broadening to include consumption of products that are currently GST-free 50% of commercial conveyancing duty From the table above, it is evident that an increase or broadening of the GST would provide for the removal of smaller and less efficient taxes that disproportionately affect small business. Recommendation R&CA supports in principle the broadening of the GST to include fresh food and produce to allow for the removal or abolition of less efficient taxes, while reducing the compliance burden on hospitality operators in determining GST credits in their business. Page 11

12 Fringe Benefit Tax R&CA has long advocated for changes to the Fringe Benefits Tax (FBT) system, recognising the compliance cost to small business is proportionately higher than for large corporations. This argument has centred on the inequity that exists in the ability of small businesses to employ strategies to avoid FBT compared to big business (i.e. big business is able to use strategies to avoid FBT, such as boardroom catering). In a 2007 report on the compliance costs of FBT on small business it was found that while very few small businesses pay fringe benefits tax, some small businesses undertake considerable compliance activities in order to avoid being included in the FBT system 8. In addition, research conducted by PricewaterhouseCoopers found that the heaviest compliance surtax incurred by business in Australia relates to FBT and the mean FBT surtax for the small/medium enterprise sample is 31.2 per cent 9. This means that the cost to small business in complying with FBT is a staggering $0.31 for every $1.00 in FBT paid to the Australian Government. The following table demonstrates the minimal FBT revenue collected from small business: Table 2: Micro-businesses: Taxpaying profile, Taxpayers and $ tax liability Income Tax Goods & Services Tax Fringe Benefit Tax No. of entities $ million No. of entities $ million No. of entities $ million Individuals 1,532,079 16, ,524 1, Partnerships 368, ,708 14, Trusts 215, ,550 1,755 3, Companies 689,915 6, ,228 3,607 18, Total 2,805,625 22,261 2,007,010 7,958 22, Source: ATO. Based on tax returns processed to 18 May 2007 for entities that have lodges their income tax return. Data is rounded to nearest $ million. The GST turnover threshold was $50,000 in The hospitality sector is further affected by the FBT system due to the treatment of restaurant meals as employee fringe benefits, as opposed to a legitimate form of doing business. R&CA in its submission to the Henry Tax Review as well as the 2007 Treasury study on small business tax 8 Commonwealth Government of Australia (2007) Scoping study of small business tax compliance costs - A report to the Treasurer, Dec PriceWaterhouse Coopers (2009) Small and Medium Enterprises Total Tax Contribution Report, December 2009, p.8 Page 12

13 compliance costs highlighted that there are 39 different ways to classify a business meal for taxation purposes. In a report prepared by Access Economics, it was found that FBT on business meals is overly complex and distorts market decisions. FBT on business meals over taxes 87 per cent of the Australian population, with 23 per cent of revenue collected being expended on compliance 10. Further, concerns have also arisen in the sector over the implications of the $5,000 cap on salary sacrificed meal entertainment and facility leasing expenses announced in the Federal Budget. On the basis of the compliance cost and lack of access to strategies to minimise the burden of FBT, R&CA argues that small businesses should be exempt entirely from FBT under the Small Business Entity concessions. Small businesses with a turnover of less than $2 million currently receive concessions on FBT for car parking; R&CA contend these concessions should be extended to include all FBT. Recommendation Small businesses with an annual turnover less than $2 million should be exempt from paying FBT entirely under the Small Business Entity concessions. 10 R&CA (2001) The Case for, and Economic effects of, Part-recognition of business entertainment as legitimate business inputs or expenses for taxation purposes prepared by Access Economics. Page 13

14 Superannuation and Working Holiday Makers Australia s superannuation system was intended to deliver retirement savings to the economy, reducing the pressure on Australia s welfare system. There are, however, instances of leakage from the current superannuation system, in particular, contributions made for Working Holiday Makers (WHM). As the tourism and hospitality sector is one of the largest employers of WHM, they bear a disproportionate burden of processing contributions. Despite promoting the collection of superannuation contributions to WHM, very few collections are made. This is either because the amount of the contribution is so small that it is not worth rolling into another fund (due to the cost of administration fees), or they are unable to collect the funds from outside Australia. As a result, employers bear the administrative burden of making contributions with no net benefit delivered to the employee or the economy. R&CA notes the changed tax treatment of temporary WHM flagged in the budget, due to be implemented 1 July R&CA notes that the treatment of collected superannuation may also change under these arrangements. R&CA advocates that any superannuation contributions made for overseas workers that are not collected are contributed to an education training fund. Superannuation Guarantee The Superannuation Guarantee (SG) threshold was established in 1996 at $450 per month at a time when the minimum wage was $9.19 per hour. However, under the Restaurant Industry Award 2010, the SG threshold is $350 per month. Today the minimum wage under this Award is $17.29 per hour (an 80 per cent increase on 1996), yet the SG threshold has remained the same. Based on the growth in the minimum wage, the SG threshold should be approximately $630 per month or $1890 per quarter. R&CA recommends the SG threshold be raised to $1800 per quarter and that it be indexed to CPI. Recommendation Remove the requirement to pay superannuation to overseas workers including Working Holiday Makers. Superannuation that is not claimed or collected by the Australian Government should be contributed to education training fund. Raise the Superannuation Guarantee Threshold to $600 per month ($1800 per quarter) and index to CPI. Page 14

15 FOREIGN AFFAIRS & TRADE Tourism Australia The industry fully supports Tourism Australia as Australia s tourism marketing agency, dedicated to increasing international visitation from Australia s major source markets. As Australia s largest services export, the efforts of Tourism Australia are critical in driving interest and visitation to Australia as a travel destination. Maintained funding for Tourism Australia allows the agency to build on campaigns already in market, providing the private sector with greater confidence to invest in cooperative partnerships developed by this organisation. Tourism Australia s Restaurant Australia campaign has delivered significant benefits to the hospitality industry, with a 12.6 per cent increase in food and wine spend by international visitors ($4.7 billion in total expenditure), as well as a 22 per cent increase in the consideration of Australia as a holiday destination with great food, wine and local cuisine 11. The reach of this initiative could not be achieved by small tourism businesses alone, given the market failure that exists in tourism promotion. Initiatives such as Restaurant Australia raise the profile of the sector with international visitors, encouraging greater patronage of Australia s restaurants once visitors land in Australia. Industry strongly encourages the Australia Government to maintain funding for Tourism Australia and the Restaurant Australian campaign in real terms over the period. Recommendation Maintain funding for Tourism Australia and initiatives that promote Australian food and wine experiences to international visitors. 11 Tourism Australia (2015) Restaurant Australia Results Page 15

16 EMPLOYMENT Registered Organisations The restaurant and catering industry has one of the highest proportions of small business owners in the country. Approximately 93 per cent of restaurants, cafes and catering companies are small businesses 12. The regulation of the labour market under the Fair Work Act 2009 and associated employment legislation creates excessive red tape and spiraling labour costs for small and medium size businesses. Ensuring these organisations understand their obligations under the Fair Work Act is critical in lifting the productivity of the hospitality sector, and a key role of registered organisations. Given the significant reforms proposed to the regulation of registered organisations, R&CA advocates that funding be allocated to effectively educate these entities on their new legislative obligations to ensure compliance and greater accountability to the members in which they serve. Recommendation Adequately fund education programs for registered organisations on their new legislative obligations to ensure compliance and greater accountability. 12 ABS (2014) Cat Counts of Australian Businesses, including Entries and Exists, Jun 2009 to Jun Page 16

17 IMMIGRATION Immigration outreach officers In , the Government announced it would cease the operation of the Outreach Officer Program delivering a budget saving of $11.2 million. The accommodation and food services sector is the largest user of the temporary skilled migration program, with over 15,000 primary visa holders in Australia as at 21 December Cooks and Café and Restaurant Managers represented the top two nominated occupations for primary visa holders in , representing 6,510 and 4,820 positions respectively. The Outreach Officer Program offered timely and industry-specific advice to restaurant and café operators on their requirements under the 457 visa program, and was extensively used by R&CA members. R&CA receives up to 30 calls and enquiries regarding the 457 program a week, with a majority of the enquiries focusing on employer obligations, how to meet the requirements of the application process, and how to migrate employees to permanent residency (186 and 187 visas). The lack replacement service has meant there is no avenue to access support when lodging their application, resulting in confusion, time delays and often additional costs when applications are refused. R&CA advocates that the Outreach Officer Program be re-instated in the budget to assist small businesses seeking to use the temporary skilled migration system as a means of addressing chronic labour shortages in their business. Recommendation Re-instate the Outreach Officer Program in the budget. Administration of the industry training fund In August 2015, R&CA provided comment to the 457 Integrity Review: Training Fund Contribution discussion paper. The discussion paper proposed the introduction of a contribution fee on a sliding scale based on the size of the business, with subsequent annual amounts of $400 to be paid by all business sponsors, regardless of size, for as long as the overseas worker remains in employment within that business on a Subclass 457 visa. 13 Department of Immigration & Border Protection (2015) Subclass 457 quarterly report, quarter ending at 31 December 2015 Page 17

18 While the implementation of an annualised fee structure would reduce the administrative burden in calculating the appropriate contributions to be made, small hospitality operators would bear a disproportionate burden of subsequent payments due to their size compared to medium or large-sized enterprises. Further, the discussion paper has outlined funds will be allocated by an independent panel and administered by the Department of Education and Training. R&CA has grave concerns over how funds are to be administered, and believes the proposed mechanism will see less money spent on training needed by the sector, and more money spent on bureaucracy to administer the new system. R&CA would strongly encourage that rather than instituting a government administered scheme, that Government work with existing industry-based Registered Training Organisations (RTOs) to deliver skills most in demand by the sector. Recommendation Revise proposed structure of Industry Training Fund contributions and work with industrybased RTOs to appropriately fund skill sets required by the sector. Page 18

19 EDUCATION Tax deductions for training As Australia moves towards a service-based labour market, employment in cafes, restaurants and takeaway food services is projected to grow by more than 43, 700 jobs or 8.5 per cent to November The rate of growth for this sector is expected to be higher than any other sector in the Australian economy 14. In addition, research by the Centre for the Economics of Education and Training suggests that between , Australia will require an additional 2.5 million people with VET qualifications, 1.7 million of which will need to be qualified at Certificate III level or above 15. Education and training is critical to improving Australia s productivity. A report by the Business Council of Australia indicated that an additional year of education may raise the level of productivity between 3 and 6 per cent for a country with Australia s current average education level 16. R&CA is cognisant the responsibility of up-skilling the sector is not solely that of government, but rather a significant contribution by employers is required. R&CA advocates that rather than instituting a training levy on employers, offering a tax advantage significantly increases the incentive to invest in staff training and development. Recommendation Grant employers a 120% tax deduction for expenditure on training and development. 14 Department of Education, Employment and Workplace Relations (2013) Employment Outlook to 2017, p Business Council of Australia (2007) Restoring our Edge in Education, p8 16 Business Council of Australia (2007) Restoring our Edge in Education, p8 Page 19

20 HEALTH Food Safety All businesses providing food for sale must comply with food hygiene requirements under Standards Food Safety Practices and General Requirements and Food Premises and Equipment of the Australian New Zealand Food Standards Code (ANZFSC). R&CA believes these standards are effective in providing a safe foodservice system in Australia. R&CA supports risk-based regulation where regulatory resources are targeted to deliver safe food outcomes in areas where they are most required. R&CA contends that risk classification should not be used to apply additional regulation (to standards and 3.2.3) but should rather be used by enforcement agencies (through local government) to determine where regulatory resources should be focused. In addition, the role of Food Safety Plans (FSPs) under Standard in improving food safety is questionable, evident by a range of studies which have found no correlation between the implementation of FSPs and increased food safety outcomes 17. As a result, an additional layer of administrative burden is placed on operators with no additional food safety outcomes delivered in the sector. R&CA believes FSPs should be used as a best practice and/or punitive measure. There is, however, evidence to suggest that improving food-handling practices through training can increase food safety outcomes 18. This being the case, R&CA advocates training for food handlers should be mandatory, similar to the requirements for Responsible Service of Alcohol, in addition to the requirement for trained Food Safety Supervisors. Recommendation Resource a best-practice food safety management campaign including mandatory training for food handlers nation-wide. 17 Food Standards Australia & New Zealand (FSANZ) National Food Handling Survey ( ) 18 Food Regulation Standing Committee (2011) Food Regulation Policy - Review of the 2003 Ministerial Policy Guideline Regulation Impact Statement, p. 5 Page 20

21 RESTAURANT & CATERING AUSTRALIA PO Box 121 SURRY HILLS NSW 2010 T F Page 21