1. Design Evaluation of the City
of Cape Town’s Investment
Incentive Policy
February 2016

2. Table of Contents
1. Introduction ........................................................................................................................................3
2. Policy Context .....................................................................................................................................3
3. Policy summary...................................................................................................................................4
4. Methodology.......................................................................................................................................6
5. Purpose of design evaluations............................................................................................................6
6. Scope of evaluation.............................................................................................................................6
6.1 Diagnostic analysis of status quo..................................................................................................7
6.2 Consideration of options...............................................................................................................8
6.3 Theory of change ..........................................................................................................................9
6.4 Target group................................................................................................................................10
6.5 Log frame/outcomes mapping....................................................................................................10
6.6 Planning implementation............................................................................................................10
7. Conclusion.........................................................................................................................................13
8. Recommendations............................................................................................................................16
9. References ........................................................................................................................................18
10. Annexures .......................................................................................................................................19
Annexure 1........................................................................................................................................20
Annexure 2........................................................................................................................................49
Annexure 3........................................................................................................................................63
Annexure 4........................................................................................................................................70
Annexure 5........................................................................................................................................72
Annexure 6........................................................................................................................................85
Annexure 7........................................................................................................................................86

3. 1. Introduction
The purpose of this study is to conduct a design evaluation on the Investment Incentive
Policy (IPP) and its implementation/operational plan (here forth referred to as the policy/the
IPP) as developed and implemented by the City of Cape Town (CCT) in 2013. This
evaluation involved analysing the theory of change, inner logic and consistency of the policy
that forms the basis of an intervention. This exercise also involved the assessment of the
quality of the indicators and the assumptions to determine whether the intervention is
designed to enable effective and efficient attainment of the policy objectives.
Design evaluation falls within the parameters of formative evaluation. Formative evaluations
are evaluation that generally takes place before or during a project’s implementation with the
aim of improving the project’s design and performance. During this process judgements are
made according to standards, goals and criteria of policies (projects and programs) to provide
feedback to persons working on the intervention in an attempt to improve the intervention’s
design and performance (Taras, 2005: 468).
2. Policy Context
The CCT’s IPP co-exists in an environment that offers a wide range of financial incentives
for businesses who want to start up or expand their facilities. The National Department of
Trade and Industry (2014:1) offer financial support to qualifying companies for Industrial
Development, Black Business Supplier Development, and Trade, Export and Investment
Incentives. It also offers Co-operative Development Financial Assistance (CIS) which is a
100% grant to registered primary co-operatives to improve the capabilities and effectiveness
of co-operatives (Department of Trade and Industry, 2015). The policy also co-exist in an
environment that offers The Urban Development Zone (UDZ) which is a tax incentive
administered by the South African Revenue Services aimed at emboldening private sector-led
suburban and commercial development in inner city areas (South African Revenue Services,
2009:1). Other incentives include Government Investment Incentives that provide incentives
for research and development to private-sector enterprises that are interested in the creation,
design and improvement of new products and processes, investment of capital expenditure
incentives for enterprises that want to acquire or upgrade assets in order to start up or expand
their businesses productivity capacity, and incentives for enhanced competitive advantage for

4. enterprises that want to increase their businesses competitiveness to enhance economic
growth (The South African Government. 2015).
In an attempt to be more competitive the CCT introduced further financial and non-financial
incentives to prospectively attract business to it region.
3. Policy summary
The CCT’s EDD, following a directive to promote economic growth and job creation from its
Economic Growth Strategy (EGS), assumes the role of creating and enabling environment that attract
investment into the CCT that affords job creation and economic growth opportunities in the city
boundaries (City of Cape Town, 2012: 19). The EDD then in 2013 developed the IIP not only to
satisfy its mandate but also to respond to a perceived gap that exists between the expectation of work
that subsists mainly among the youth of the city, and the low probability of finding work that prevails
in Cape Town (City of Cape Town, 2013: 4) (See Annexure 1).
Conceptually, investment incentives are considered measurable advantages afforded to specific
businesses or categories of businesses by government (United Nations Conference on Trade and
Investment, 2013: 84). The CCT designed incentive packages offering non-financial and financial
incentives to new investors and existing businesses that wish to expand their facilities in Cape Town.
These investors are only eligible to access these incentives when they meet the criteria set by the
CCT (City of Cape Town, 2013: 17).
According to the Investment Incentive Policy document (July 2013:14), the CCT offers the following
incentives to the target beneficiaries when they start a new business or expand with a facility of an
existing business:
Non-financial incentives
 Single-point investment facilitation
 Development application fast-tracking
 Regularly updated spatial economic information
 Skills development facilitation
The CCT Implementation framework (2013b, 3-4) (See Annexure 2) also states that if prospective
investors or existing businesses meet the requirements to follow, they are eligible for financial
incentives. These requirements include:
1. Starting or expanding their businesses in designated spatial areas identified by the CCT

5. 2. The main economic activities of the businesses involves manufacturing or are in the priority
sectors identified by the CCT,
3. The business providing 30 to 50 new permanent full time jobs within two years of
establishment with 75% of the jobs being occupied by South African citizens.
4. Being tax complaint with SARS.
5. The premises from which the business operates possess an occupation certificate in terms of
the National Building Regulation issued by the City
If business owners satisfy the above mentioned requirements they are eligible to receive the
following financial incentives:
 Development application fee exemption
 Development contribution deferral / debt write off (capped to a maximum of R1m per
investment)
 Electricity tariff reduction
 Broadband connection fee waiver
It should be noted that at this stage, the CCT has not identified the pre-determined, qualifying
spatial locations that qualifies businesses to receive financial incentives. As a result businesses only
qualify for non-financial incentives and not for financial incentive.
The CCT piloted an investment incentive scheme in the Atlantis industrial area in 2013. The
qualifying criteria for the pilot investment incentives scheme differs from the City-wide intervention.
Here the proposed investors only had to establish a business in the Atlantis Industrial area. No
restrictions to economic activity or location exists. All investors considering to open or expand a
business in Atlantis industrial area qualified for the following non-financial and financial incentives:
Non-financial measures
 Dedicated investment facilitation support
 Development application fast-tracking
 Biodiversity offsets
Financial measures
 Development application fee exemption
 Electricity tariff subsidy
 Development contribution deferral / debt write off (capped to a maximum of R1m per
investment) which is conditional to businesses that are able to create at least 50 new
permanent full time jobs within two years of qualifying for the DC debt deferral/write

6. off. Should the business not create at least 50 jobs within two years the business is
liable for the Development Contribution.
4. Methodology
This design evaluation was informed by 14 evaluation questions suggested by the National
Department of Monitoring and Evaluation (DPME) as guidelines to undertake and manage design
evaluation in 2014. The questions that guided the design evaluation covered the historical context, the
conceptualisation and design of the policy.
Empirical research of a qualitative nature was conducted to undertake this evaluation. This involved
reviewing documents relevant to the IIP and collecting primary qualitative data through basic
individual interviews. The interviews were conducted with the policy developers, determined through
the purposive sampling method. Clarity and confirmation on matters not clearly stated in policy
documents were solicited from policy developers. All of which was done to develop an understanding
of the intervention’s logic and theory of change. An attempt was also made to assess the relevance
and appropriateness of the IIP, its policy design, as well as its internal and external coherence.
5. Purpose of design evaluations
Design evaluations usually function to ensure that the design of an intervention is robust before it is
implemented. However since this policy has already been implemented, this design evaluation
functioned to establish the strengths and weaknesses of the design and to identify the components that
might hinder the policy’s chances of success. This was done by assessing the theory of change, inner
logic and consistency of the policy. This evaluation exercise also assessed whether the key indicators
are clear, relevant, economical, adequate and monitorable. Furthermore, this design evaluation
exercise attempted to assess whether sources of evidence are available for subsequent monitoring and
evaluation activities, and that the monitoring and evaluation system is adequate to provide the data
needed to assess the policy results and impacts. The information attained from this study will then be
communicated to the policy developers as input to the review of the policy.
6. Scope of evaluation
The evaluation covers the design of the IPP and scheme that covers the Atlantis and the entire CCT
region and the implementation/operational framework, from inception in 2013 and addresses the
following evaluation components of the policy design:
I. Diagnostic analysis of status qua
II. Consideration of options
III. Theory of change

7. IV. Target group
V. Logframe
VI. Implementation planning
The questions that will be asked to help assess the design of the policy are informed by the
Department of Monitoring and Evaluation’s Guideline on Design Evaluation (2014).
6.1 Diagnostic analysis of status quo
6.1.1 Is the need or problem the intervention addresses clearly defined and the nature and scale
of the problem clear and substantiated by good evidence?
The need for economic growth that absorbs the jobless in the Metropolis through attracting businesses
to Cape Town by means of offering incentives is clearly stated in the policy documents as the
rationale of the policy. The policy also clearly states that the perceived gap between the expectation of
work and the low probability of finding work is the problem that it aims to address. The policy
document however uses national and provincial level unemployment statistics to substantiate a local
level problem. This might be due to the lack of up to date municipal level unemployment statistics
being available, except for the old 2011 Census datasets. The lack of municipal level statistics also
impeded on the policy’s ability to accurately explain the scale of the challenges.
6.1.2 Is there a convincing analysis of the root causes of the problem substantiated with strong
evidence e.g. from research or diagnostic evaluation?
The policy documents refer to market failures as the reason for high unemployment. Furthermore, the
racial segregation of the Apartheid era was also cited as a reason for the disproportionate employment
opportunities in the city. There is however no evidence of root-cause analysis, a diagnostic evaluation
or investigative reports that provide the reasons for the high unemployment rate in Cape Town
presented in the policy documents. It can be argued that the reasons for this might be that it is a well-
known fact that South Africa and all its provinces and cities are victims to structural unemployment.
Moreover, the IIP was borne as part of the CCT five year Integrated Development Plan (IDP) and the
Economic Growth Strategy (EGS, p.12) for the CCT so the development of the policy was
predetermined and directive, hence not necessarily subject to evidence.
6.1.3 Is there a strong rationale why this is a government priority - is this part of the National
Development Plan/Outcomes or departmental strategic plan?
The rationale for the Investment Incentive Policy derives from the CCT’s Integrated Development
Plan (IDP) which houses the five year strategic plan for the CCT (2013:3). The five year plan is built
into 5 strategic areas which include making the CCT an opportunity city, a safe city, the caring city,
the inclusive city and the well-run city. The IIP in principle speaks to making the city an

8. (employment) opportunity city (City of Cape Town, 2012: 9). This in turn speaks to the Economic
Growth Strategy approved by the CCT in 2013 that mandates the Economic Development Department
to aid in making the CCT a city globally competitive city alongside mandating it to create an
environment in Cape Town that enables economic growth and job creation by attracting the
investment that generates such opportunities. Hence the rationale of strategizing this as policy priority
format is valid.
6.2 Consideration of options
6.2.1 Are the different options for addressing the root causes made clear and is there evidence
presented that these options are appropriate?
The policy fails to site proof of considering and testing alternative solutions to the unemployment
crisis in Cape Town. This is however due to it being a mandated directive from the IDP and EGS.
During an interview with one of the policy developers it was confirmed that this policy was explicitly
requested from the top structure of the bureaucracy (City leadership) as the implementation process of
the EGS and IDP. (Mr Tim Hadingham 2015, pers.comm., 28 May).
6.2.2 Are the cost/benefits of the different options made clear and the justification for selection
of the preferred implementation option convincing?
As no policy alternatives were identified and considered, no comparative cost-benefit analyses were
needed to be conducted during the development for this policy. The costs and benefits for the
incentives policy was not modelled during the policy development phase of this intervention. This
created a situation where it could not be determined whether the direct and indirect benefits this
policy proposes to bring would outweigh the financial and administrative costs to the CCT before the
policy was implemented. It also deprived the CCT of reconsidering the proposed policy and
considering another policy intervention that could have been more cost effective and/or have a bigger
impact.
One of the policy developers communicate that economic modelling was nevertheless done for the
policy at a later (Mr Tim Hadingham 2015, pers.comm., 28 May). The economic model assessed the
impact of the implementation of the financial component of the City-wide investment incentive. This
economic evaluation, that was done close to a year after the policy was designed and implemented,
assessed how much land would be occupied by businesses if it took up incentives, how much the CCT
could accrue in revenue from these businesses and it determined the minimum employment
opportunities that could be created if businesses took up the incentives. The economic model also
determined how much it would cost to provide one job per sector for the CCT and how long it will
take the CCT to earn the money back it spent on incentives. The modelling further compared how

9. much the CCT is spending per job in comparison with other existing job creation initiatives if
incentives were taken up. (See Annexure 4)
This exercise, done in retrospect attempts to inform stakeholders what it would cost the CCT if the
incentives were taken up and how much it would cost the CCT to create one job if incentives were
provided to a certain number of businesses owners. The model also provides some guidance on the
feasibility and the sustainability of the policy intervention. Again, if this exercised was done
prospectively and policy alternative were identified and economically assessed, the CCT could have
perhaps identified more cost-efficient ways of attracting investment and creating jobs, at a more
sustainable and financially feasible rate.
6.3 Theory of change
6.3.1 Is there a clear Theory of Change explaining the causal mechanism for achieving the
desired outcomes and impacts?
A 'theory of change' is exactly what the term state: it is a theory (thus not proven) that states how a
particular intervention, with particular resources and processes, will bring about a desired change
through its processes and outputs.
To prove whether the theory of change is true, we adopt a series of indicators that 'measure change
over time'. The indicators help us to assess whether the theory of change is working as intended.
This is often captured as a Logical Framework (logframe), where the logframe systematically presents
the underlying 'theory of change’ with its indicators.
The review of the policy documents did not avail the inclusion of the necessary inputs (resources such
as people, information, finance, support) required to plan, coordinated and implement, the set of
activities and processes necessary to deliver certain outputs that would assist in attaining the desired
policy outcomes and eventual impact of the policy program. The policy documents thus did not
manage to illustrate how the policy and its implementation plans propose to effect change. This leads
to the impression that the necessary preconditions that need to be in place to achieve the outcomes and
impact of the policy was not identified nor duly considered. Furthermore, there is no evidence that

10. and the causal links (relation between an event (the cause) and a second event (the effect), between
the resources needed and activities/ tasks to be completed to achieve the outcomes and effect the
impact was done was identified. This makes it difficult to assess and forecast whether the policy will
have the desired outcomes.
This fact, according to TH (perr.com 28 May 2015) can be attributed to the CCT is guideline to policy
writing (See Annexure 5) does not prescribe that policy developers need to conduct a theory of
change exercise when developing a policy. The before mention policy encourages identifying and
asserting the different parts of theory of change – the inputs, activities, and outcomes- however the
policy does not prescribe the before mentioned in a cause-effect relationship.
6.4 Target group
Is the target group clear and are there clear measures to see who is in/out, and progress?
The policy explicitly states that new investors looking to start a business and existing businesses
who are looking to expand facilities in the Cape Town municipality parameters are the target group.
The policy further then states that these specific groups must also prescribe to specific criteria to be
able to access the proposed incentives which further delimit the target group.
6.5 Log frame/outcomes mapping
6.5.1 Is there a log frame/outcomes mapping?
The policy documents do not include a systematic, visual illustration of how it approached the
designing, executing and assessment of the policy processes. The policy documents also do not
illustrate to readers the relationships between available resources, planned activities, and desired
changes or results. Furthermore, no hierarchy of objectives or the development pathway of the policy
intervention from which one can best understand how the intervention will affect the desired change
in behaviour of investors was demonstrated. Again, this is not required from policy developers in the
CCT according to its “Guidelines to policy writing” hence it is not a necessity for CCT policies to
include in policy documents.
6.6 Planning implementation
A thorough implementation plan usually includes a work plan as well as the resources, expertise,
capacity and budget needed to implement the work plan. It affectively also identifies stakeholders,
includes a comprehensive risk assessment and risk matrix, outline quality control measures, it outlines
the methods that will be used to track performance and contains a communication plan as a basic
minimum (Stellenbosch University, 2015: 55).

11. The CCT produced an “Operational framework for the administration of investment incentives” in
October 2013 (See Annexure 2) which constitute as its implementation framework for the Investment
Incentive policy.
The framework includes an introduction to the Investment Incentive Policy, an outline of the incentive
packages, the qualifying and counter-performance criteria and an outline of the administrative
process/list of activities which the officials of the Administration will carry out in introducing
stakeholders to the investment incentive and providing the incentives to the interested stakeholders.
The administrative process also outlines who will undertake certain activities and who will record the
range of different incentives taken up by the investors and existing businesses. This implementation
plan also infers that existing staff will be used to do the administrative tasks outlined in the
implementation framework.
The framework also communicates that a pilot study is being introduced in the Atlantis industrial
area. During the review of the policy documents it is also availed that the pilot project offers slightly
different incentives to investors in Atlantis against different criteria to that of the city-wide Investment
incentive policy. These variations in incentive package offers, does not only open the door to various
discrepancies and conflict between investors, but does not give a true reflection of what results the
intervention can produce if implemented.
6.6.1 Is there an appropriate activity schedule for the activities?
The list of the activities to be executed to effectively implement the intervention is outlined in the
framework provided. The list however only outlines what needs to be done once the CCT is
approached by the target group for the intervention. A review of the policy documents and
implementation plan does not contain a communication plan and planned activities to communicate
the policy information to the target group. The lack of a communication strategy leaves a substantial
gap in the activity schedule and gives the impression that the crucial activity has not been executed.
Thus, the knowledge about the incentives is left to chance and the outcomes of the policy is
compromised.
Although, the desktop review of the policy documents stated that the policy and its content was
published in weekly and weekend newspaper once upon adaptation of the policy for public
participation, the probability of the target group having access to those specific publications at the
time it was published, is low.

12. Furthermore, the activity list alludes to the collection of data and keeping record of it which can be
accepted for the monitoring of data, but it fails to mention any activities relating to evaluations and
the development of a Monitoring and Evaluation system for the policy intervention.
6.6.2 Is the human resource required to implement the intervention clear, realistic and
available?
The activity schedule suggests that the existing officials in the different departments will be identified
to fulfil the necessary tasks needed to implement the investment incentive policy. The fact that these
identified human resources are realistic and available is uncertain. The uncertainty is embedded in the
lack of a theory of change and a logframe which usually summarises the human resources needed to
effectively and efficiently complete all the tasks that result in the different outputs that will lead to the
outcomes. However, because the theory of change and the logframe/outcomes mapping exercise was
not done, one is unsure of how much staff is needed to complete the tasks of the policy intervention
efficiently to produce the stated outputs effectively in order to attain the desired outcomes.
Furthermore, if the existing staff are expected to take on additional tasks related to the implementation
plan, to their existing the implementation plan, it leads, either to staff being overloaded with work to
keep up with policy implementation tasks and their initial work duties, or the policy implementation
tasks will not take priority and might not be implemented efficiently and effectively.
One of the policy developers did however communicate that, new employees will be recruited to the
programme once the programme is performing at a positive rate and if there is reasonable uptake by
companies (TH, 2015, pers.comm. 28 May).
6.6.3 Are there appropriate management arrangements within the department for running
the intervention?
The implementation plan as well as the policy developer (TH, 2015, pers.comm, 28 May) states that
an official has been appointed to manage the intervention as a whole.
6.6.4 Are there roles that have to be played by other role players in or outside government
and are all of the roles envisaged funded mandates?
Three directorates within the CCT are identified as essential role players in the delivery of the
investment incentives intervention. There is however no visible evidence of any service level
agreements between the Economic Development Department and the Transport for Cape Town, the
Utilities Department and the Finance directorate outlining the scope, quality, responsibilities,
turnaround times or delivery times of the services being delivered by these role players in the policy
documents. This insinuates that because the performance management, customer duties and even the

13. definitions of service was not agreed upon or clearly outlined in a service level agreement it cannot be
enforced.
6.6.5 Is there an M&E capacity established including a budget for evaluations and have these
been programmed?
The framework suggests that the Economic Development Department will conduct the monitoring
and evaluation of the policy however no indicators, targets, planned resources, milestones and outputs
are easily observable in the policy documents, thus it is uncertain what is going to be monitored and
evaluated.
Furthermore, it appears that the there is no budget for the IIP. This means, that even with monitoring
mechanisms in place, there will not be any warning signs as to when saturation point is reached, when
there is overspending or when they have incentivised too little as there is no budget to measure
against.
The lack of budget also means no funds were ring-fenced for this process.
6.6.6 Is there a risk management plan? Does this take into consideration the assumptions?
The desktop review of the policy documents indicates that the risks that might deviate the CCT’s
endeavours to reach the desired outcomes of attracting investment that brings job opportunities to the
unemployed of the city was not identified, assessed, prioritised, hence it cannot be minimized,
monitored or controlled. One of the policy developers did confirm that no formal risk management
exercises were followed during the policy development phase.
The absence of the risk management exercise creates the impression that the policy intervention is
operating in financial market uncertainty, threats from project failure, legal liabilities, credit risks and
unpredictable root-causes among other things. The lack of risk management exercise also deprives the
policy of operating with contingency plans should any of the risks arise. Furthermore, the failure to
conduct a risk assessment restricts the CCT’s ability to capitalise on different opportunities that the
risk assessment process brings to the table. Moreover, the lack of risk management planning means no
assumptions are taken into consideration (Kusek and Rist, 2004:20).
7. Conclusion
The purpose of this evaluation was to determine the strengths and weaknesses of the design process of
the Investment Incentive policy and its implementation plan, to identify the components that might
hinder the success of the intervention, to assess whether the key indicators are clear, relevant,
economical, adequate and monitorable and to assess whether sources of evidence are available for

14. subsequent monitoring and evaluation activities. This report also functioned to assess whether the
sources of data is adequate to provide the data needed to assess the policy results and impacts. It also
strived to assess the theory of change, inner logic and consistency of the policy design.
The following strengths were identified:
 The target beneficiaries are clearly identified as new businesses and existing businesses that
intend on expanding their facilities in the CCT region and not merely relocating businesses.
 The policy also clearly states the criteria the target group has to prescribe to in order to access
the incentives.
 The policy documents also clearly conceptualises investment incentives.
 There is adequate alignment of the policy to the regulatory and legislative framework of the
CCT, the Western Cape and South Africa in terms of attempting to create employment
opportunities.
 Considerable attention was given to the international practices of investment incentives.
The following weaknesses were identifies:
 No evidence of a root cause analysis that demonstrates the “cause” of the social problem is
effecting the population.
 Absence of evidence that alternative options to address the current challenges were
considered.
 The policy document does not adequately demonstrate what resources will be invested in
what activities to deliver the range of products to the recipients that will ensure the
beneficiaries’ current social status is changed.
 The absence of a logical framework/outcome mapping for the intervention prevents one from
comprehending the inner logic for the intervention.
 The activity list seems incomplete as it does not provide information on how policy
information is going to be communicated to the target group and also does not list how the
information is going to be monitored and evaluated.
 The lack of communication strategy and plan for the policy implementation probes
accessibility problems for the intended recipients and beneficiaries.
 The lack of budget not only raises questions about the sustainability of the intervention but
also limits the cost efficiency analytical abilities of those wanting to assess and evaluate that
aspect of the intervention.
 The policy documents communicates the Economic Development Department will conduct
monitoring and evaluation however no budget seems to accompany this proposal.

15.  The policy document seems to lack a Monitoring and Evaluation framework and system, thus
the policy staff will not be able to advise whether the intervention is performing satisfactory,
reaching objectives, underperforming and achieving the intended outcomes. It needs to be
comprehended that merely taking up of incentives does not necessarily mean success.
 The fact that no new officials were appointed to implement the policy enables one to make
the assumption that the work load of the implementation of this policy will bring will just be
added to the current officials’ workload and the policy implementation will not accord high
priority
 The policy documents indicate that a risk management exercise was not conducted during the
designing of this policy. This deprives the policy implementers to recognise the risk when
they appear and furthermore restrict their capacity to take action against the risk if it
approaches them. Additionally, policy implementers are also restricted in their capacity to
capitalise on opportunities positive risks brings. The lack of risk management also means no
contingency plans exist for when the time arises to operate according to it.
The above mentioned weaknesses also constitute components that might hinder the success of the
policy intervention. Due to the lack of the theory of change, logic model and economic evaluation
conducted, one can also not establish whether the policy intervention can be implemented efficiently,
and effectively. The lack of the above mentioned information also creates reservation about the
likelihood that the intervention will produce the desired outcome. The absence of a root cause
analysis, makes one question whether we are addressing the root cause of unemployment and
opportunity gap problem. Furthermore the fact that no alternatives were considered to justify the
policy choice.
Moreover, the financial viability of this intervention has not been determined, thus the sustainability
of the intervention itself is not determinable. Furthermore, due to the lack logical sequential cause-
effect steps in the form of a theory of change or log frame the probability of success of the
intervention cannot be forecasted. Additionally, because the risks to the intervention was not
identified, assessed and can therefore not be managed, the prospects of the intervention is
unidentifiable.
The lack of dedicated human resources, budget and capacity to the intervention also renders the
possibility of success questionable. If officials are expected to add the workload of policy intervention
to their existing workload the chances of the intervention activities receiving the full amount of
energy and enthusiasm it needs is low.

16. The likelihood of great uptake of the incentives by investors or existing business is also small as there
is no plan to communicate the policy information to the investors. There needs to be a communication
strategy in place within the implementation plan which mandates designated staff to ensure the target
group is aware of the incentives the CCT offers.
Thus due to the lack of theory of change, logframe, and incomplete implementation arrangements the
likelihood of the intervention working is unconvincing. This lack also repudiated the exercise of
determining the quality of the indicators and restricted the assessment of the assumptions to determine
whether an intervention is designed to make it possible to effectively and efficiently meet its stated
objectives. This all demonstrates that the design of the policy can affect how the policy objectives are
attained effectively and efficiently.
8. Recommendations
 It is recommended that, the policy developers, during the policy review consider developing a
theory of change/outcomes map for the policy. The theory of change/outcomes map will
assist policy developer to demonstrate a linear path of cause and effect. It will also position
the policy programme within a wider analysis of how change will be effected and assist the
Department in articulating its understanding of how it intends for change to occur.
Furthermore, the theory of change/outcomes map will challenges the developers to explore
the intervention further by considering the wider systems in which the policy exist and the
environment and actors that influence it (James, 2011: 4).
The development of a theory of change/outcomes map will further strengthen the precision,
efficacy and motivation of policy intervention, provide a basis for monitoring, evaluation and
learning throughout a policy cycle and help to communicate work clearly to others and utilise
the theory as a reporting framework.
Policy developers should in undertaking the exercise to think openly about change and how it
happens, looking at the context for change, at organisational and not only project level. James
(2011:3) also recommended that the policy consider the following when developing the
theory of change:
 Who the CCT’s IIP target group is and why.
 Who and what influences the target groups’ lives.
 The long term changes that needs to realise in the target groups lives.
 What the CCT’s contribution will be to this change.
 What the ultimate visualisation for change is.

17.  What environmental changes need to affect to achieve these changes.
 What groups need to be influences to help affect the change.
 What changes need to be affected in them.
 What aspects, associations, methods and paths will induce change at each level.
 What the three to five key aspects to which associations can contribute that will be
vital in bringing about change.
 What the rationale or thinking behind the thoughts that change will transpire that
way.
 What the external and internal risks that might preclude change from taking place.
 How might the approach need to be tailored to specific groups.
 How the City will measure if change has happened.
 How the lessons learnt be applied back into the City.
 It is also recommended that following the theory of change/outcomes mapping exercise
policy developers develop a logical framework (logframe) for the policy intervention which
will basically involve identifying the strategic elements -inputs, outputs, outcomes, impact-
and their pivotal and underlying relationships amongst the before mentioned and stakeholders
and developing indicators that will enable one to measure the strategic elements and its
delivery. It is also advised that policy developer consider the assumptions or risks that may
influence success and failure of the policy programme when developing the logframe. This
exercise will enable further strategic planning of the intervention, help plan the execution and
facilitate the evaluation of the intervention (Kusek and Rist, 2004: 227).
 It is advisable that the policy developers undertake economic evaluations for the interventions
to establish the financial viability of the policy programme to inform a budget and contribute
to sustainability of intervention. Conducting this type of evaluation will enable the policy
developers to determine whether the policy costs outweigh its benefits, assess whether the
policy is providing value for money, and determine the net social benefit resulting from a
policy (The Presidency, 2014:3).
 Furthermore, it is prudent that the policy developers assess the factors that might affect the
intervention’s successful implementation by conducting a risk assessment and compile a risk
matrix. This will enable the policy implementers to manage the risks, capitalise on it when
possible and put contingency plans in place (Kusek and Rist, 2004: 223).
 Compile a communications strategy that will address who the recipients of information will
be, in which format the recipients will receive the information, by when, and who will prepare
and disseminate the information (Kusek and Rist, 2004:130).
 Draw up service level agreements to bind service department and also ensure accountability.

18.  The human resources element for both the policy implementation and monitoring and
evaluation need to be reconsidered. Policy managers need to consider whether adding the
policy implementation activities to exiting staffs existing work load will give the before
mentioned the desired priority. The policy developers should also consider the capacity and/or
expertise of those identified to conduct the monitoring and evaluation exercises for the policy.
 Compile a monitoring framework for the interventions.
 Developing a monitoring and evaluation system for the intervention.
 Policy developers also need to consider a budget for evaluation.
 Greater attention should be given to research before policy development as researching root
causes of problems, gap analyses and economic evaluation of policy alternative can only
ensure that the policy adopted and implemented is the most cost efficient and effective policy
alternative that is actually addressing the problem at hand.
9. References
 City of Cape Town. 2013. Investment Incentive Policy: Request to review and rescind council
resolution C99/07/13 of July 2013 report. Available online at:
https://www.capetown.gov.za/en/Treasury/Documents/InvestmentPolicy_Feb_2013.pdf. [20
January 2015].
 City of Cape Town. 2012. Integrated Development Plan (IDP) 2012/13 Review. Available
online at: http://www.capetown.gov.za/en/IDP/Documents/IDP12_final_May12.pdf. [27
April 2015].
 City of Cape Town. 2013. Operational framework for the administration of investment
incentive report. Available at: City of Cape Town. [20 January 2015].
 James, C. 2011. Theory of change review: A report Commissioned by Comic Relief.
Available online at: http://www.theoryofchange.org/pdf/James_ToC.pdf [12 March 2015].
 Kusek. J and Rist. C. 2004. Ten Steps to a Results- Based Monitoring and Evaluation System.
The World Bank, Washington, DC.
 Stellenbosch University. 2015. Public sector monitoring and evaluation: 5 day training Course
Reader. 21 May, University of Stellenbosch.
 Taras, M. 2005. Assessment – summative and formative- some theoretical reflections. British
Journal of Educational Studies, ISSN p. 466–478. Available online at:
http://onlinelibrary.wiley.com/doi/10.1111/j.1467-8527.2005.00307.x/abstract [3 March
2015].
 The Department of Trade and Industry. 2014. A Guide to Incentive Schemes 2014/
2015. Available at:

19. http://www.thedti.gov.za/financial_assistance/financial_assistance.jsp [Accessed 07
June 2015].
 The Department of Trade and Industry. 2015. Co-operative Development Financial
Assistance (Incentives). Available at:
https://www.thedti.gov.za/financial_assistance/financial_incentive.jsp?id=11&subth
emeid=3 . [Accessed 07 June 2015].
 The Presidency. The republic of South Africa. Guideline on Design Evaluation. Available
online at: http://www.thepresidency-
dpme.gov.za/keyfocusareas/evaluationsSite/Pages/Guidelines.aspx#. [24 April 2015].
 The Presidency. The republic of South Africa. Guideline on Economic Evaluation. Available
online at: http://www.thepresidency-
dpme.gov.za/keyfocusareas/evaluationsSite/Pages/Guidelines.aspx#. [24 April 2015].
 United Nations Conference on Trade and Investment. 2013. World Investment Report 2013:
Global Value Chains: Investment and Trade for Development. Available online at:
http://unctad.org/en/PublicationChapters/wir2013ch3_en.pdf. [27 April 2015].
10. Annexures
1. Investment Incentive Policy
2. Operational framework for the administration of investment incentives
3. Transcribed interview
4. Modelling the impact of the implementation of the financial component of the City-wide
investment incentives
5. Guideline to policy writing
6. Interview guide

20. DRAFT – FOR DISCUSSION ONLY
CITY OF CAPE TOWN
INVESTMENT INCENTIVES
(POLICY NUMBER 12506)
APPROVED BY COUNCIL : 28 AUGUST 2013
C29/08/13
Annexure 1

21. 0
CITY OF CAPE TOWN
INVESTMENT INCENTIVE POLICY
A. Document Control
Director Thembinkosi Siganda
Executive Director Japie Hugo
Version 2
Document Status Final
Next Review date June 2015
Reference Codes
Contact Details 021 – 417 4019

22. CONTENTS
DEFINITIONS AND ABBREVIATIONS ...................................................................................................... 23
1. PROBLEM STATEMENT..................................................................................................................... 25
2. STRATEGIC FOCUS AREAS ................................................................................................................ 25
3. Background ...................................................................................................................................... 26
4 DESIRED OUTCOME........................................................................................................................... 29
5 ALIGNMENT WITH IDP PRINCIPLES AND OBJECTIVES....................................................................... 29
6 PURPOSE OF POLICY DOCUMENT..................................................................................................... 30
7 SCOPE OF APPLICATION.................................................................................................................... 30
8 REGULATORY CONTEXT..................................................................................................................... 30
9 EXISTING INVESTMENT ENABLING ENVIRONMENT.......................................................................... 31
10 POLICY DIRECTIVE DETAILS ............................................................................................................. 33
12 IMPLEMENTATION, EVALUATION AND REVIEW............................................................................. 37
13 REFERENCES.................................................................................................................................... 37
ANNEXURES .......................................................................................................................................... 38

23. DEFINITIONS AND ABBREVIATIONS
For the purposes of this policy, except where clearly indicated otherwise, the words and expressions
set out below have the following meanings:-
“Approved budget” means an annual budget which is (a) approved by a municipal
council and includes such an annual budget as revised by an
adjustments budget in terms of section 28;
“By-Law” Means legislation passed by the council of a municipality binding
in the municipality on persons to whom it applies
“City” means the City of Cape Town, a Metropolitan Municipality
Constituted in terms of the Local Government: Municipal
Structures Act, 1998, read with the Province of the Western Cape:
Provincial Notice 479/2000 dated 22 September 2000
“Council” means the Council of the City of Cape Town,
established by Provincial Notice 479 of 2000 issued in
terms of section 12 of the Municipal
Structures Act, 1998;
“Delegation” In relation to a duty, includes an instruction to perform the duty,
and “delegate” has a corresponding meaning.
“Executive Director” Means a person appointed by the Council to head a Directorate
in the City and shall include any person acting in that position or
to whom authority is delegated.
“Executive Mayor” Means the person elected in terms of section 55 of the Municipal
Structures Act to be the Executive Mayor of the City and shall
include any person acting in that position or to whom authority is
delegated.
“Mayoral Committee” Means the committee appointed by the Executive Mayor to assist
the Executive Mayor in terms of Section 60 of the Municipal
Structures act
“Sub-council” Means a Council - an area in the metropolitan municipality- which
is established in terms of the Municipal Structures Act

24. Abbreviations
AoD
City (CCT)
CHEC
DC
DTI
Acknowledgement of Debt
City of Cape Town Municipality
Cape Higher Education Consortium
Development Contribution
Department of Trade and Industry
EESP Economic, Environment and Spatial Planning
EGS
ICT
Draft Economic Growth Strategy
Information and Communications Technology
IDP
IPAP
PBDM
Integrated Development Plan
Industrial Policy Action Plan
Planning and Building Development Management
PGWC Provincial Government of the Western Cape
SEZ
SMME
Special Economic Zone
Small, Medium, Micro Enterprises
SCM Supply Chain Management
SDF
SIC
SSO
TRS
UNCTAD
WTO
Spatial Development Framework
Standard Industrial Classification
Sector Support Organisation
Transport, Roads and Storm water
United Nations Conference On Trade And Development
World Trade Organisation

25. 1. PROBLEM STATEMENT
The Quarterly Labour Force Survey (QLFS, 2013) for the 1st
quarter of 2013 reflects an official
unemployment rate of 25.2% for the country and an unemployment rate of 23.3% for the Western
Cape. These aggregate statistics mask a problem which is even more pronounced among the
country’s youth. Although the country shed large numbers of jobs during the global recession in
2009, employment, according the QLFS, has grown by 199,000 in the past year. Employment
growth, however, has simply not matched labour force growth to accommodate the (typically
young) individuals who enter the labour market with the expectation of finding decent work. This
gap between the expectation of work and the low probability of finding work, is potentially
destabilising for South Africa and the Western Cape, and is a contributing factor to a range of social
ills afflicting the City of Cape Town. In recognising these challenges the City has prioritised the
creation of sustainable and decent work opportunities.
Unemployment is not only concentrated among the youth but is also concentrated in certain spatial
areas within the City. Census 2011 data shows vast disparities in unemployment rates for different
regions within the City of Cape Town. These disparities are largely formed along arbitrary dividing
lines designated during the Apartheid era. Job creation is critical to uplifting these areas. While job
creation is central to the City’s developmental mandate, it is important to recognise that the City
cannot be the sole or even the main provider of employment opportunities. The Cape Town IDP
(2012:15) reflects that “only business can create the sustainable jobs that this city and our country
so desperately need”. In this respect, private sector investment is crucial. The IDP (2012:9) further
states that the City of Cape Town aims to “create an enabling environment to attract investment
that generates economic growth and job creation”. This policy document focuses on the use of
incentives to increase private sector job-creating investment, particularly in high unemployment
regions within the metro.
Mid-sized cities, like Cape Town, in developing countries are playing an increasingly central role as
drivers of growth in the global economy. Inter-city competition to attract investment and business
talent is expected to intensify alongside the rapid expansion of urban economic activity, a trend that
demands that Cape Town develops a consolidated position on the use of investment incentives.
With foreign direct investment1
in South Africa declining by more than 5% in 2012, while other
African countries such as Nigeria grew foreign direct investment by 20%, it is imperative that the City
has a well-informed strategy to promote confidence in the local economy (FDI Intelligence, 2013:12).
An investment incentives policy is an important component of a broader strategy to attract
investment in the City.
2. STRATEGIC FOCUS AREAS
1
Measured in number of new projects

26. This policy document aims to inform and guide the provision of incentives for job creating
investment within the city of Cape Town.
For any city administration, the question of how to design a comprehensive incentives strategy must
be located within both a global and local context. For the City of Cape Town, the local context
demands that the administration performs a careful balancing act: While incentives packages can
play a role in encouraging investment that is critical for driving economic growth and job creation,
the City must also be cognisant of the revenue implications of these programmes and how this
impacts on the administration’s capacity to address its other strategic policy priorities and service
delivery.
While research tends to indicate that incentives are rarely the most important factor in location
decisions by business, they do influence decision making and can play a “tipping point” role. Non-
financial incentives, particularly with respect to transparent and consistent administrative
procedures are often considered by investors to be more important than incentives with a direct
financial benefit. It is the role of the City to identify the best mix of both non-financial and financial
incentives.
Although there are a wide range of incentives offered by other spheres of government, most notably
the Department of Trade and Industry (DTI), the City of Cape Town desires to see these national
incentives complemented by a set of incentives that relate to the mandate of local government. The
context-specific investment incentive package detailed in this policy document is designed to
respond to investment-limiting challenges on the ground at a local level in the city. Utilising
investment incentives to create a more conducive environment for private sector investment will
position the city of Cape Town as a preferred investment destination both in South Africa and
globally.
3. BACKGROUND
3.1 Defining an Investment ‘Incentive’
An incentive is broadly understood to be a special intervention designed to change the behaviour of
economic actors or to influence their decisions in order to achieve specific outcomes. Defining an
‘investment incentive’ as compared to incentives more generally is complex and there is no standard
definition. The UNCTAD, however, define an investment incentive as “any measurable advantage
accorded to specific enterprises or categories of enterprises by or at the direction of government”
(Barbour, 2005:2). According to this definition, an across the board reduction in taxes or an
improvement in other investment related conditions for all investors, is not considered an incentive.
This is because incentives must be ‘specific’, namely they must be restricted to investors who meet
given criteria such as locating in a specific area or operating in a specific economic sector.
Investment incentives are often defined according to their typology or the nature of the outcome
they are trying to achieve. The following types of investment incentive are recognised: (Barbour,
2005:2)

27. • Direct financial incentives: Including grants; loans at low interest
• Indirect fiscal incentives: including tax rebates and tax holidays
• Other non-fiscal incentives: including regulatory and administrative concessions; and
subsidised or reduced service costs
3.2 Rationale for Incentives
Investment incentives are used as a tool by governments to boost investment and to stimulate
economic growth and employment creation within a particular region. Incentives are most
commonly and appropriately used to achieve pre-defined strategic objectives contained in strategy
or policy documents (such as an IDP). These objectives are specific and aim to induce investors to
“shift an investment decision towards a particular region, sector or project” (SAIIA, 2012:13). This
notion is elaborated by the economist Paul Barbour (2005:3) who describes incentives as biasing
“investors’ decision-making positively in favour of investments in certain sectors or regions”.
Local Governments use incentives to achieve an outcome which the market may not achieve on its
own. Market failure is regarded as the primary justification for the use of investment incentives by
local government. Barbour (2005) identifies examples of market failure which may be addressed by
incentives. These are listed below:
• Positive externalities: This refers to business’ inability to account for the broader social
impact of their investment, leading them to undervalue the return on their investment and
under-invest as a result. Positive Externalities are often observed with regard to Research
and Development spending where the social return is significantly higher than the private
return. Incentives would look to optimise the level of R&D spending by narrowing the gap
between the private return and social return.
• Infant Industry2
: Barriers to entry and anticipated risk for new businesses may result in
under-investment in a sector or geographical locality. “Markets often fail to correct for the
gains that can accrue over time from declining unit costs and learning by doing” (Barbour,
2005:4). Incentives can be used to address this market failure by supporting businesses in
overcoming barriers to entry in the start-up phase. The assumption underpinning this
thinking is that once these barriers to entry are dealt with the market will self-correct.
• Information Asymmetries and Uncertainty: A lack of information regarding a particular
under-developed geographic area or emergent economic sector may result in under-
investment by raising the level of uncertainty and the expected risk of new investment for
businesses. Even though the net return on investment may be positive, in the face of poor
information, investors are risk-averse. In particular, companies may face ‘first-mover
disadvantage’ whereby the first company to invest takes on all the risk of investment in the
new area, while other companies benefit from improved information as a result of the first
business’ initial investment. Incentives may be used to overcome this first-mover
disadvantage and enable the subsequent creation of ‘agglomeration effects’ as other
companies take advantage of improved information availability.
Other reasons for investment incentives:
2
Any incentive aimed at support infant industries must be in accordance with the WTO’s stipulations

28. • Equity considerations: Investment incentives may not only be used to correct market
failure but also to address the inequitable distribution of the market and to reverse
historically engineered inequalities. Economically depressed areas get caught in a trap of
low existing private investment levels hindering future private investment. Incentives may
be used to break this circular pattern of underinvestment. Caution must apply to the use
of incentives in this way, as research has regularly shown that incentives in a weak
investment climate tend to be ineffective.
• International Competition: In an increasingly globalised world economy, wherein capital
can be shifted around relatively freely, local governments compete on a global scale for
private-sector investment. They may do this by providing competitive tax rates and service
charges. This has the potential danger, however, of resulting in a ‘race to the bottom’, as
local governments undercut one another to the extent that the marginal benefit is smaller
than the associated revenue loss.
• Signalling intent: Investment incentives may, in some instances, be more symbolic than
substantive and act as a signal to investors that an economy or local area is open for
business.
• Regulatory barriers to entry: Regulatory failure as much as market failure can be an
impediment to new investment. Some of the onerous application and registration
processes for new developments can act as barriers to entry for new investment in an area
or sector. Regulatory failure is often exacerbated in under-developed areas as the
administrative infrastructure can be similarly under-developed. While a Citywide reduction
in red-tape may be desirable in the long-run, regulatory fast-tracking or compliance
concessions that can be phased-in within specific priority geographic areas or sectors can
be effective incentives to attract investment in these areas.
The above reasons for providing investment incentives resonate with the City of Cape Town to
varying degrees. Generally, as outlined in the problem statement to this policy document, the City
desires to improve competitiveness in a bid to attract international investment. The City must be
mindful however, that incentives alone do not create competitiveness, and should be directed rather
at the removal (or counterbalancing) of blockages to investment and the harnessing of existing
investment potential. Certain marginalised areas within the metropolitan area have substantial
economic potential but are hindered by entrenched perceptions of risk; uncertainty; barriers to
entry; and ‘first mover disadvantage’. Investment incentives will be used by the City as a tool to
overcoming disincentives to otherwise viable investment. The proliferation of these disincentives in
previously disadvantaged areas implies that an investment incentives policy will help enable the City
to reduce income inequality. It will also send a strong signal to business that the City is serious
about fostering private sector investment and creating a healthy business climate in these areas.
3.3 A functional definition of Investment Incentives for the City of Cape Town
In order to transparently guide this investment incentives policy, it is imperative to provide a
functional definition of an investment incentive for the City of Cape Town.
Henceforth in this document an investment incentive will refer to:

29. A time-limited measurable advantage, aimed at the rectification of market or regulatory
failure, afforded to a business by the municipality either through administrative/regulatory;
financial or fiscal means for job-creating investment within a targeted geographic area and/or
industry.
There are two crucial elements of the above definition, namely, addressing market failure, and
targeting. Research by the World Bank (2010) has shown that incentives cannot compensate for a
poor investment environment. As such investment incentives should only be used to address
instances where market or regulatory failure discourages investors from investments which could
yield significant private and social returns. By addressing actual barriers to entry or disincentives to
investment, this would avoid the ‘free-rider’ problem associated with incentives when investors who
had already planned to invest in an area take advantage of the incentives on offer. Similarly,
effective targeting, by focusing on areas or sectors in which disincentives exist, will also ensure that
the municipality does not unnecessarily lose revenue as a result of free riding. Targeting is also
essential in tying investment incentives to the City’s broader spatial and sector development goals.
4 DESIRED OUTCOME
The Investment Incentives Policy aims to attract investment to Cape Town with a specific focus on
making it a preferred business destination. In particular, the City of Cape Town desires investment
that addresses the objectives and development challenges articulated in key documents such as the
Integrated Development Plan, the Spatial Development Framework and the draft Economic Growth
Strategy. At the forefront of these objectives, and in alignment with the National Development Plan
and New Growth Path for the country, is the creation of sustainable employment opportunities.
The Investment Incentives Policy will assist and guide the City in managing incentive related
activities in an efficient and effective manner so that the desired outcomes can be achieved. The
purpose of the investment incentives policy is not to develop a package of subsidies to support
unsustainable business models but rather to encourage investment that meets the City’s vision and
objectives. Furthermore, the investment incentives policy will assist in the targeting of desirable
investment in particular spatial locations that require intervention.
5 ALIGNMENT WITH IDP PRINCIPLES AND OBJECTIVES
The strategic focus areas of the City are enshrined in the City’s Integrated Development Plan (IDP)
and are categorised into five pillars: These five pillars are namely the Opportunity City, the Well-run
city, the Safe City, the Caring City and the Inclusive City.
Although incentives can have an impact on all five pillars, this policy focussed mostly on the
Opportunity City and the Inclusive City.
The underlying principle of the Opportunity City in relation to investment incentives is the attraction
of business investment that creates sustainable employment, contributes to the development of key
sectors and catalyses development in important spatial nodes. In the long term the right kind of
investment will create the platform for a sustainable growth path for the City of Cape Town.

30. The underlying principle of the Inclusive City is to ensure accessibility for Cape Town’s residents to
employment and business opportunities. This includes direct employment created by firms investing
in the City but also in terms of indirect employment within local firms supplying goods and services
to new investment.
6 PURPOSE OF POLICY DOCUMENT
The purpose of this Investment Incentives Policy document is to:
• Define the range of non-financial incentives available
• Define the range of financial incentives available
• Establish criteria concerning the spatial and sectoral targeting of the incentives so as to
ensure the City’s broader goals are achieved.
• Provide a schedule of incentives available to eligible investors describing the scope of the
financial and non-financial incentives offered by the City of Cape Town, as well as the
processes to be followed when applying for the incentives.
7 SCOPE OF APPLICATION
The City’s Investment Incentives Policy applies to incentives aimed at job creating investment,
offered by the City of Cape Town within the remit of its constitutional mandate and within the City’s
jurisdictional area.
8 REGULATORY CONTEXT
The policy is developed and guided by the following legislation and regulations:
• The Constitution of the Republic of South Africa :Act 108, 1995, section 156 (1) (a), read with
Part B of Schedule 4
• Municipal Finance Management Act (MFMA) Act No 56 of 2003 and related regulations
• Municipal Property Rates Act (MPRA) Act No 6 of 2004
• City of Cape Town System of Delegations
• City of Cape Town Integrated Development Plan
• City of Cape Town draft Economic Growth Strategy
• City of Cape Spatial Development Plan
• Provincial and National Built Environment Legislation
• Draft National Policy Framework for Municipal Development Charges

31. 9 EXISTING INVESTMENT ENABLING ENVIRONMENT
Attracting job-creating investment to the City of Cape Town necessitates the development of a
comprehensive and multi-faceted investment attraction and promotion strategy. Investment
incentives are only one component of such a strategy. Crucial to the success of any investment
incentives policy, is the need to foster a conducive environment for investment. Incentives are
never a suitable substitute for physical infrastructure provision, access to consumer or labour
markets, or good governance. However a strong investment/business environment incorporating
these factors is a critical enabling factor for a successful package of incentives. The creation of an
enabling environment for investment is a key focus of the City of Cape Town.
The City of Cape Town as an investment destination benefits from excellent infrastructure, including:
South Africa’s second largest container Port; an international airport; a comprehensive road and rail
network and rapidly expanding broad band infrastructure. These factors among others (i.e. the
strength of the business community; skilled labour etc.) are determinants of the locational
attractiveness of the City for investors. In addition to these locational factors, investors in the City
can benefit from a number of existing national and City of Cape Town incentives which aim to
further enhance the attractiveness of the City and, in some instances, to correct for market or
regulatory failure. These existing investment enabling factors are identified below:
9.1 National Investment Enabling Factors
The Department of Trade and Industry offer a number of investment incentives in a range of sectors.
The relevant incentives for investment attraction or expansion, offered by the DTI are listed below:
• AIS (Automotive Incentive Scheme)
• BBSDP (Black Business Supplier Development Programme)
• BPS (Business Process Services Incentive Programme
• CTCIP (Clothing and Textile Competitiveness Improvement Programme)
• Co-operative Incentive Scheme
• EIP (Enterprise Investment Programme)
• FIG (Foreign Investment Grant)
• Film and Television Incentive
• Foreign Film and Television Production and Post-Production Incentive
• MCEP (Manufacturing Competitiveness Enhancement Programme)
• MIP (Manufacturing Incentive Programme)
• PI (Production Incentive)
• CPFP (Capital Project Feasibility Programme)
• ISP (incubation Support Programme)
• SPII (Support Programme for Industrial Innovation)
• Tax Allowance Incentive for Greenfield and Brownfield Investments
National Treasury
• Urban Development Zones (UDZs)

32. Special Economic Zones Bill
The draft SEZ policy defines an SEZ as “a geographically designated area/s of a country, set aside for
specifically targeted economic activities which are supported through special arrangements which
may include laws and often support systems that are different to those applied in the rest of the
country.” (DTI, 2011) An SEZ Bill was recently introduced to the National Assembly by the Minister
of Trade and Industry. This Bill essentially seeks to regulate the designation, development,
promotion, operation and management of Special Economic Zones (DTI, 2013). The Bill includes
provision for regulatory measures and tax and business incentives to attract investment.
Atlantis has been proposed by the City of Cape Town in conjunction with Western Cape Provincial
Government as the location of a Green Technology Park SEZ. The outcome of this proposal is
dependent on the findings of a pre-feasibility study to be conducted by the DTI. While the material
extent of incentives offered by SEZs has yet to be finalised by the DTI, the establishment of Atlantis
as an SEZ would expand the scope of incentives that could be offered to businesses and have
profound implications for the attraction of investors to the area.
9.2 Municipal Investment Enabling Factors
The City utilises a number of area-based management tools aimed at improving the business
environment of specific areas. These include:
• City Improvement Districts (CIDs): Usually takes the form of the provision of
supplementary and complementary services provided by a non-profit organisation
operating within a defined geographic area. CIDs are created by local business owners to
provide “top-up” cleaning and security services.
• Mayoral Urban Renewal Programme (MURPS) – this programme aims to uplift areas
that have been identified as neglected and dysfunctional through the maintenance of
public infrastructure and facilities in order to stabilise areas and provide a platform for
more effective public and private investment.
• Area Co-ordinating Teams (ACTs) – are a mechanism to enhance consultation
between the CCT and its citizens. ACTs are a platform for politicians, officials and
communities to debate and reach consensus on issues relating to planning, housing,
healthcare and infrastructure.
• Urban Development Zones (UDZs) – The UDZ is a tax incentive administered by
National Treasury that aims to address urban decay in South Africa's inner cities by
promoting private sector-led investment in commercial and residential developments.
• Provincial Strategic Objective 1: Creating opportunities for growth and jobs –
Although this a provincial objective, the CCT strongly subscribes to the “red tape to a red
carpet” approach to enhancing the business environment that it advocates.
• Sector Support Organisations – the CCT provides grant funding support to a number
of sector support organisations including Wesgro. These organisations undertake a number
of support and advocacy activities aimed at the development of a particular sector.

33. 10 POLICY DIRECTIVE DETAILS
In order to promote effective management of incentives in the City of Cape Town
Municipality the following policy directive details will apply.
10.1 General Principles
The following principles have been applied to the development of the incentive packages described
in Annexure 2.
Principle 1: Employment Creation
The investment incentives must be tied to the attainment of the City’s developmental goals of which
job creation is foremost. The goal of incentive provision is not to simply enhance business profit
margins with little or no broader socio-economic impact. Rather, investment incentives must be
used to support and enhance job-creating private sector investment. In this respect a business’
eligibility for incentives should be conditional upon the creation of a prescribed number of jobs.
Principle 2: Affordability
The incentives package must not place undue pressure on the City’s Finances such that the City is
not able to meet its service delivery targets. In this respect, the City should not sell services below
cost to business. Where possible, high impact but low cost ‘soft incentives’ such as expedited
approval times; and increased administrative efficiency in the dealing with applications, should be
targeted. Financial incentives should be prudent and aim at removing a barrier to entry or counter-
balancing a locational disincentive as opposed to simply subsidising businesses. The impact of
financial incentives should be carefully modelled and limits on financial incentives should be
implemented where deemed necessary.
Principle 3: Transparency and Uniformity
The incentives should be non-discriminatory in terms of WTO regulations, and should be applied
with uniformity and transparency. As such the granting of investment incentives should be done
according to a set of predetermined criteria. This set of criteria will be consistently and, without
prejudice, applied to all businesses applying for incentives. Information on the nature of the granted
incentives should be public knowledge.
Principle 4: Sectorally Targeted
The investment incentives policy should support the development of the City’s prioritised,
comparative advantage sectors. International research on investment incentives has shown that
incentive packages work best when they are strategically targeted to enhance competitiveness
through agglomeration and clustering. Effective industry agglomeration can greatly enhance the

34. attractiveness of a location for investors. As a result, the City’s investment incentives policy should
be supportive of industries in which Sector Support
Organisations (SSOs) operate and those prioritised in the City’s Integrated Development Plan (IDP);
the Global Competitiveness Study and the draft Economic Growth Strategy (EGS). While these
sectors may receive prioritisation, (as provided for in transparent incentives criteria) investment in
other industries/sectors may also be considered according to the criteria detailed below.
Guiding criteria for incentives provision: The investment must enhance the City’s value-added
productive capacity – this is to say that the eligible investments should be in the manufacturing
sector.
Research (SAIIA, 2012:12) on investment incentives has found that incentives are most effective
when targeted at efficiency-seeking (manufacturing) investment as opposed to market-seeking
(retail) or resource-seeking (mining; agricultural) investment. The focus, in the main, on the
manufacturing sector is in alignment with the goal of the Industrial Policy Action Plan 2013-2016 of
“preventing industrial decline and supporting the growth and diversification of South Africa’s
manufacturing sector”. It is also consistent with the focus of the Special Economic Zones
Programme on the manufacturing sector.
Principle 5: Spatially Targeted
International best practice has found that investment incentives are most effective when they are
spatially targeted. This is for the following reasons:
• Spatial targeting ensures that incentive provision, by having defined parameters is
affordable for the City (refer to Principle 1)
• Spatial targeting reduces the occurrence of ‘free-riding’ by excluding areas with strong
existing investment flows and with minimal impediments to new investment
• Spatial targeting can assist in removing area-specific blockages to investment or systemic
market or regulatory failure
• Spatial targeting enables the City to achieve its development objectives in specific areas
thereby addressing issues of spatial inequality
Guiding criteria: Investment incentives should be provided in areas where there is significant
potential for job-creating investment but where impediments to investment currently exist.
Areas will be selected based on a process currently being undertaken in which over 70 business and
industrial nodes across the city are tracked by systematically assessing their current performance
and long-term growth potential.

35. Principle 6: Simplicity
Ascertaining whether a business is eligible for an incentive and subsequently obtaining an incentive
should not be an onerous task for investors. The criteria for incentive provision should be easy to
understand. Deadweight loss as a result of administrative complexity needs to be minimised. The
structure and administration of the investment incentives should not require excessive
administration, thereby minimizing staff and financial impacts. This will also ensure quick turnaround
times for applications (urgency and speed is essential to attract and retain investment).
Principle 7: Legality
The incentives that are provided must be subject to the relevant legislation and planning
parameters. Incentives cannot be in conflict with national legislation nor should they be provided to
companies which are not in compliance with the law. The investment incentives policy must also be
in line with national and provincial planning guidelines.
Principle 8: Complementarity and alignment
Both national and provincial government currently provide various programmes and packages that
incentivise investment and job creation. Incentives offered by the City should align with these in
order to enhance their impact. Furthermore, the City’s incentive should directly reflect is mandate
as a separate and independent sphere of government i.e. it should relate to incentives that the City
can uniquely provide.
Principle 9: Continuous Review
In order to stay competitive in a global economy that is constantly changing, this policy should be
reviewed regularly. There are two pertinent reasons which underpin the need for continuous
review. The first reason for continuous review is that the needs of investors are dynamic and
respond to changes in the global economy. A shift in production techniques may result in a particular
incentive no longer being an effective factor in influencing the decision of where to locate. To stay
responsive to the dynamic nature of investment, it is essential that the investment incentives policy
be regularly reviewed. The second reason for continuous review is that the true impact of the
incentives on investment decisions will only be apparent when the investment incentives policy is
implemented. As such it may be necessary to make adjustments to the original policy specification
in light of lens learnt post implementation.
Any additional investment incentives that the City will offer investors outside those proposed in this
policy will be required to conform to the above principles.
10.2 Incentives Design
The previous section outlined the general principles guiding the formulation of incentives. While
these general principles speak to the scope of incentives; administration of incentives; and the type

36. of criteria which should be applied to the incentives, they are not specific to the design of the
incentives.
Best Practice Design Elements
Drawing on international best practice, there are a number of design elements which are considered
to characterise efficient and effective investment incentives3
:
• Provides a degree of predictability and certainty: While continuous review is necessary,
incremental rather than wholesale adjustments should be made to the incentives schedule.
A degree of continuity is important for investor confidence.
• Should be upfront and target start-up impediments to investment
• Includes limits on expenditure or taxes foregone to the fiscus
• “Incorporates sunset clauses for both the scheme itself and for the duration of benefits to
any one firm” (Barbour, 2005:9)
• Incorporates claw-back causes if pre-established targets are not met
• Must be ‘on-budget’: the fiscal impact of the incentives must be modelled, and
accommodated for in the City’s budget
10.3 The Incentives Package
Details of the incentives offered by the City of Cape Town to investors can be found in Annexure 2.
For the purposes of brevity, the type of instruments and not the specifics of each instrument are
described below. The incentives have been categorised according to whether there is a financial
implication for the City or not.
Non-Financial
• One stop investment shop
• Fast tracking of development applications
• Investment facilitation officers
• Targeted marketing and promotion
• Facilitation with DTI to obtain relevant incentives
• Provision of spatial economic information
• Skills development assistance
• Access to sector support organisations
3
Modified from Barbour, 2005, An Assessment of South Africa’s Investment Incentive Regime with a Focus on
the Manufacturing Sector

37. Financial
• Reduced building plan application costs
• Reduced land use management application cost
• Rebates on Development Contribution
• Rebates on property tax
• Reduction in service charges
It should be noted that the financial incentives contained in Annexure 2 are indicative and are
subject to further engagement with Corporate Finance and other affected Directorates. In
particular, the provision of financial incentives will be conditional on the outcomes of a revenue
impact modelling exercise.
11 IMPLEMENTATION, EVALUATION AND REVIEW
This policy framework provides the administrative procedure for the management of investment
incentives offered by the City of Cape Town. To this end the following shall apply:
• The Investment Incentives Policy shall be implemented once approved by Council
• The individual incentive will be implemented by the appropriate line department as indicated in
Annexure 2 and will be co-ordinated by the Economic Development Department’s Economic
Development Facilitation unit in consultation with the Investment Facilitator located in the
Mayor’s office.
• Incentives will not be automatically applied to new development, but will be the result of an
application process. Prospective investors will be advised by the Economic Development
Facilitation unit with respect to the application procedure.
• Monitoring and evaluation will be performed by the Economic Development Department’s
Economic Information and Research unit.
• Directorates are to advise the Economic Development Department: Economic
Information and Research Unit of challenges with respect to implementation of the policy
• An implementation procedure will be developed for approval by the City Manager that will
address inter alia:
• The application process and system (including forms)
• Roles and responsibilities of decision makers
• The recording system
• The progress tracking the auditing system Monitoring and evaluation.
• Any amendments to this policy must be re-submitted to Council for review and approval after
the necessary public participation process.
• This policy should be reviewed and updated within two years of being approved by council.
12 REFERENCES

38. • Barbour. P, 2005, An Assessment of South Africa’s Investment Incentive Regime with a
Focus on the Manufacturing Sector in ESAU Working Paper 14
• City of Cape Town, 2012, 5 Year Integrated Development Plan (IDP): 2012-2017
• FDI Intelligence, 2013, The FDI Report 2013: Global Greenfield Investments
• James. S, 2010, Providing Incentives for Investment: Advice for policymakers in developing
countries in Investment Climate in Practice No.7, January 2010
• Minister of Trade and Industry, 2013, Special Economic Zones Bill in in Government Gazette
No. 36203 of 1 March 2013
• National Treasury: Intergovernmental Relations, 2013, Policy Framework for Municipal
Development Charges: Final Draft, Version 7
• The Department of Trade and Industry, 2013, Industrial Action Plan 2013/14 -2015/16
• Wentworth. L, 2012, South Africa’s Investment Landscape: Mapping Economic
Incentives in SAIIA Occasional Paper No.105
ANNEXURES
Annexure 1 – Qualifying Criteria for Investors
Annexure 2 – Schedule of Investment Incentives

39. MICHELLE JOJA - 17373042 39
ANNEXURE 1 - QUALIFYING CRITERIA FOR INVESTORS
There are four qualifying criteria determining the investor’s eligibility for incentives that are progressively applied. These criteria are detailed in the table below.
Qualifying Criteria
1. General Criteria The investment must constitute a new ‘external’
4
investment or the expansion of an existing investment in the area, and
cannot simply be a relocation of businesses already based in the City.
2. Spatially targeted Investment incentives will only be available to businesses investing in pre-determined qualifying spatial localities.
The targeting of specific areas is essential to reduce the occurrence of ‘free-riding’ which might undermine the affordability of
the incentives scheme, as well as to ensure that the City’s development objectives are met.
Areas will be selected based on a process currently being undertaken in which over 70 business and industrial nodes across the
city are tracked by systematically assessing their current performance and long-term growth potential.
The number of incentive applicants allowable or the extent of the time period for which applications will be accepted will vary
according to the specific spatial characteristics of the identified business or industrial nodes. Location specific limits on the
number of businesses which can obtain the investment incentives will ensure that the City can manage the fiscal cost of
incentive provision while responding to the different development objectives the City has for different areas.
4
I.e. Constitutes a new investment in the City

40. MICHELLE JOJA - 17373042 40
3. Sectorally Targeted The investment must be in a sector which enhances the value-added production
5
capacity of the city of Cape Town. The
proposed investment (except where otherwise stated in the priority sector list) should be located in the manufacturing sector.
All investments in the manufacturing sector, subject to meeting the relevant criteria, are eligible for incentives. However a
number of sectors are prioritised by the City in alignment with the City’s strategic economic development objectives. These
priority sectors are derived from the City’s IDP and draft Economic Growth Strategy (EGS) and are in alignment with the
Industrial Policy Action Plan 2013-2016. The incentives will be structured accordingly around this prioritisation.
The following sectors will be eligible for investment incentives
Broad Manufacturing Sector (SIC 3)
Priority Sectors:
 Oil and Gas Processing (SIC 412; 2212; 332)
 Boat Building (SIC 384)
 Business Process Outsourcing
 ICT (SIC 752; 86)
 Creative industries (SIC 326; 961)
 Agro-processing (SIC 30)
 Green technology (SIC 36; 395; 411)
 Medical technology and pharmaceuticals (SIC 374; 3353)
 Finance and Insurance (SIC 81; 82; 83)
4. Employment Creation The investment must create new and sustainable full time employment in the pre-identified areas to be eligible for the
incentives package. In order to most effectively achieve the City’s development objectives, the employment criteria are lower
for investments in the specific priority sectors. This is elaborated on below
5
Value-added production: the processing of raw or transformed input materials such that the value of that input is enhanced – typically manufacturing

41. MICHELLE JOJA - 17373042 41
Group A
Sector/Industry: Broad manufacturing sector (other than
those identified as priority sectors)
Employment Criteria: Large investments resulting in more
than 50 people being permanently employed after 24
months.
Group B
Sector/Industry: Priority productive sectors
• Oil and Gas Processing
• Boat Building
• Business Process Outsourcing
• ICT
• Creative industries
• Agro-processing
• Green technology
• Medical technology and pharmaceuticals
• Finance and Insurance
Employment criteria: Large investments resulting in more
than 50 people being permanently employed after 24
months.
75% of the jobs created in each of the categories must be occupied by South African citizens. The onus is on the
Investor to provide auditable and verifiable evidence as may be specified by the City Manager from time to time.

42. MICHELLE JOJA - 17373042 42
ANNEXURE 2 - SCHEDULE OF INVESTMENT INCENTIVES
Category Description Actions and responsibilities
EXISTING INVESTMENT INCENTIVES

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National Investment Incentives (not
subject to foregoing qualifying criteria)
The Department of Trade and Industry offer a range of
incentives for new investors and businesses looking to expand.
• AIS (Automotive Incentive Scheme)
• BBSDP (Black Business Supplier Development
Programme)
• BPS (Business Process Services Incentive Programme
• CTCIP (Clothing and Textile Competitiveness
Improvement Programme)
• Co-operative Incentive Scheme
• EIP (Enterprise Investment Programme)
• FIG (Foreign Investment Grant)
• Film and Television Incentive
• Foreign Film and Television Production and Post-
Production Incentive
• MCEP (Manufacturing Competitiveness Enhancement
Programme)
• MIP (Manufacturing Incentive Programme)
• PI (Production Incentive)
• CPFP (Capital Project Feasibility Programme)
• ISP (incubation Support Programme)
• SPII (Support Programme for Industrial Innovation)
• Tax Allowance Incentive for Greenfield and
Brownfield Investments
• The proposed designation of Atlantis as a Special
Economic Zone (in terms of the SEZ Bill produced by
the DTI), would greatly enhance
• Agency service to facilitate the access to relevant
national incentives for eligible
investments (Economic Development
Facilitation Unit)
• Develop a comprehensive investment incentives
guidebook for the City of Cape Town (Economic
Information and Research Unit)
• Lobby national (DTI) and provincial government to
establish a Special Economic Zone in Atlantis
(Wesgro/Economic Development Facilitation
Unit)

44. MICHELLE JOJA - 17373042 44
The ability of the City to attract investors to the area.
National Treasury also offer the Urban Development Zones
(UDZ) incentive
Sector-Targeted Financial Grants The City funds Sector Support Organisations that provide
support in the following areas:
• Trade and investment
• Marketing and promotion
• Business process outsourcing
• Information technology
• Craft and design
• Clothing and textiles
• Fashion design
• Oil and gas
• Furniture
Align SSO functions with new investment incentives
policy (Economic Development
Facilitation Unit)
Facilitate access for new investors to programmes run
by the SSOs (Economic
Development Facilitation Unit)
PROPOSED INCENTIVE SCHEME
(The following incentives are only offered to eligible businesses in terms of the foregoing eligibility criteria)
Non-financial measures
Single-point investment facilitation Applies automatically
• Facilitation with DTI to obtain relevant incentive
packages
• Investment One Stop Shop for development
applications. This will take the form of a vertically
integrated office consolidating national and local
application and registration processes.
• Access to a dedicated investment facilitation officer
to walk the investor through the various
administrative processes
Provide single point of entry to potential investors
(Investment Facilitator in the
Mayor’s Office)
Facilitate the access to relevant national incentives for
eligible investments (Economic Development
Facilitation Unit)
Facilitation of access to the various incentives offered
by the CCT (Economic Development Facilitation
Unit)

45. MICHELLE JOJA - 17373042 45
Development Application Fast-
tracking
Applies to all land use and building applications by eligible
companies in pre-identified areas (only for complete
submissions)
Timeframe commitment as follows:
Review and adjustment of relevant processes to
reflect timeframe commitments (PBDM )
• Land use application - 3 months
• Building plan decisions- 2-5 days
Regularly updated spatial economic
information
Applies automatically
• Eligible investors will receive regular reports on the
socio-economic and business environment in which
they have located
• Eligible investors within priority sectors will be
provided with regularly updated market intelligence
reports
Annual fact sheets outlining socio-economic
conditions and state of the business environment in
pre-determined qualifying spatial localities
(Economic Information and Research Unit)
Bio-diversity offsets Applicable where environmental impact authorisation for
new development in pre-identified area requires biodiversity
conservation. The City of Cape Town is holding land for
nature reserve purposes which may offset these impacts. To
be evaluated on a case by case approach within different
localities.
Development of a set procedure by which developer
can ‘apply’ to benefit from off-set land.
Develop a recoding mechanism. (ERM)
Skills development Applies automatically
• The City will use its partnerships with tertiary
institutions (CHEC) to assist in matching business’
demand for relevant labour force skills with the
supply of skills (through the provision of relevant
courses and qualifications at tertiary institutions).
• Through the SSOs the City will fund industry specific
training and skills development courses
Facilitate the access to relevant skills bodies and
support organisations for eligible investments
(Economic Development Facilitation Unit)

46. MICHELLE JOJA - 17373042 46
Financial Incentives
Application Fees Automatic full exemption for both land use and building plan
application fees, only in areas designated by Council.
Report to council to approve revised (exempted) tariffs
(PBDM)
Development Contribution Upon application, only in areas designated by Council.
Applies in respect of both civil and electrical DCs where
enhanced development rights granted
100% DC debt write off up to a limit of R1 million conditional
upon job target being achieved after 24 months.
The DC debt will still be calculated and Acknowledgment of
Debt (AoD) signed as per normal; AoD only becomes payable 24
months after payment would normally have been required (i.e.
instead of normal immediate payment), unless job creation
target achievement proved by beneficiary company, in which
case 100% debt write-off up to R1 million. This effectively
amounts to either deferred debt payment (at worst), or it may
translate into full debt write-off against budgetary provision (at
best).
Incentive only valid for 24 months from date of application
approval.
The incentive will only be available for a specified number of
applicants on a ‘first come first serve’ and a ‘use it or lose’ it
basis.
DC exemptions subject to National Treasury guidelines as
outlined in the Policy Framework for Municipal
Development Charges 2013
Estimate incentive take-up (Utilities/TRS) Separate
report to Council to amend current DC policy to
accommodate Atlantis pilot (Utilities/TRS) Model
revenue impact & make budgetary provision
(Utilities/TRS)
Create budgetary mechanism for realisation of revenue
foregone (i.e. debt write-off) (Finance)
Establish application procedure, recording system
& audit mechanism (Economic Development
Facilitation Unit/Economic Information and
Research Unit/Finance)

47. MICHELLE JOJA - 17373042 47
Property tax rebate Upon application, only in areas designated by Council. Create procedure and necessary budgetary mechanism
for rates rebate (Finance)
Rebates apply to developed property only, as follows:
Year 1 = 100%
Year 2 = 66%
Year 3 = 33%
Year 4 = no rebate
Rebate repayable at the end of Year 2 and the end of Year 3,
unless achievement of the job creation target is proved by the
beneficiary company (thus amounting to either rebate at best
or deferred payment at worst)
Electricity tariff subsidy Upon application, only in areas designated by Council.
Time of Use tariff to be increased at a discounted rate, subject
to NERSA approval and annual inclusion into Council’s Tariff
book, from year of application for a period of two years.
To be reviewed annually
Obtain NERSA approval (Utilities)

48. MICHELLE JOJA - 17373042 48
Counter performance criteria and
proviso’s
• No development within 12 months, or incompletion of
the development within 24 months will result in the
incentives becoming obsolete.
• The stipulated job targets should be reached not later
than the second year of operation, failure of which will
result in all incentives becoming obsolete and deferred
payments becoming payable
• The investment must be consistent with the provisions
of the District Spatial Development Framework as
approved by Council
• The applicant and all business associated with it, must
be in good standing with the Council and SARS, and will
be required to produce a tax clearance certificate in
order to apply for incentives
• The premises out of which the business will be (is)
operating must be in compliance with the
National Building Regulations and Standards Act
• The investment must comply with the applicable
environmental, labour and heritage legislation.
All financial incentives are subject to the council
budgeting processes as prescribed by National
Treasury.

49. 49
CITY OF CAPE TOWN
OPERATIONAL FRAMEWORK FOR THE
ADMINISTRATION OF INVESTMENT INCENTIVES
OCTOBER 2013
Annexure 2