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BrewCo's each have an excise licence to manufacture beer and have their own manufacturing facilities. 2. BrewCo's have no loans between each other. 3. BrewCo's do not have common shareholders. 4. Each BrewCo has a distribution agreement which outsources the sales, marketing and distribution function to DistroCo for their beer. 5. Each BrewCo calculates and pays excise and claims the remission on the beer that it manufactures and sells to DistroCo on an excise-paid basis. 6. DistroCo collaborates with each BrewCo to determine the best mix of products made by the BrewCo to meet the demands of the marketplace. 7. DistroCo is not an alcohol manufacturer. 8. In this circumstance, each BrewCo is legally and economically independent to claim the remission.