100% income tax exemption forfive years of assessment on statutory income in respect of specified qualifying activities in the shipping and creative sectors. The WHT is payable within 20 days after the interest payment was made. The largest source of government revenue. US ITS Practice Leader, PwC United States, Stay updated with our regular tax insights. An additional tax at a rate of 3% applies on an individual's income if their income from all sources in a tax year exceeds ILS 640,000 (in 2017). Under certain treaties, the exemption or reduction in rate also does not apply if the property producing the income is attributable to a fixed base in the United States from which the recipient performs independent personal services. Based on the announcement, any taxpayer can appeal the rental value assessment. Under Israeli domestic tax law, WHT on payments of Israeli-source income is generally deducted at the corporate tax rate from all income remittances abroad, unless a tax certificate is obtained from the ITA authorising withholding-exempt remittances or a reduced rate of tax pursuant to an applicable tax treaty. By submitting your email address, you acknowledge that you have read the Privacy Statement and that you consent to our processing data in accordance with the Privacy Statement. AFSI determines whether a corporation is an applicable corporation subject to tax as well as the amount of the tax. The New Zealand corporate income tax (CIT) rate is 28%. Italy It is proposed that these incentives, which expired on 31 December 2020, be extended until 2022, with details to be announced later. 5% for interest in connection with the sale on credit of any industrial, commercial, or scientific equipment or on any loan of whatever kind granted by a bank. Other non-fiscal incentives available include: A concessionary tax rate of 10% for five years (renewable for another five years) will be given to a newly incorporated resident company in Malaysia that uses Malaysia as its international trading base for undertaking strategic sourcing, procurement, and distribution of raw materials, components, and finished products to its related and unrelated companies in Malaysia and abroad (for applications by 31 December 2022). There are no state or municipal income taxes in New Zealand. 2017 - 2022 PwC. However, certain tax objects or industries have special tax regimes. 5% if the beneficial owner directly holds at least 10% of the capital of the company paying the dividends. Partial tax exemption (income taxable at normal rate): Chargeable income (SGD*) Exempt from tax: The AMT FTC reduces 15% of a taxpayers AFSI to arrive at the tentative minimum tax. Royalties: The rate is 10% of the gross amount of the royalties; 0% for copyright royalties for and other like payments in respect of the production or reproduction of any literary, dramatic, musical, or artistic work (excluding royalties in respect of motion picture films and royalties in respect of works on film, videotape, or other means of reproduction for use in connection with television broadcasting); and 0% for royalties for the use of, or the right to use, computer software or any patent or for information concerning industrial, commercial, or scientific experience (but not including any such royalty provided in connection with a rental or franchise agreement). Your message was not sent. 5% of the gross amount of the dividends if the beneficial owner of the dividends is a company (other than a partnership or a real estate investment company) that directly holds at least 25% of the capital of the company paying the dividends; and 15% of the gross amount of the dividends in all other cases. Customs duties are imposed on imported goods at rates that vary according to official categories. 5% if the beneficial owner of the interest holds 50% or more of the capital of the company paying the interest; 0% if the beneficial owner of the interest is a pension plan of the other contracting state or the government of the other contracting state; 10% in all other cases. 188 on 26 March 2020, taxpayers are required to issue their invoices electronically as per the technical and legal requirements that were issued by the head of the ETA. Singapore However, as noted above, P.L. Malaysia has a wide variety of incentives covering the major industry sectors. ITA of 100% for five years for existing companies in Malaysia to relocate their overseas manufacturing facility for a new business segment to Malaysia with a minimum investment of MYR 300 million. Tax preference or adjustment items could arise, for example, if a corporation had substantial accelerated depreciation, percentage depletion, intangible drilling costs, or non-taxable income. 10% if the beneficial owner is a company (excluding partnership) that directly holds at least 10% of the capital of the paying company. A corporation that is a member of a foreign-parented multinational group must apply a two-part test. Such exemptions are not separately indicated in the table above. Interest will be taxable at a maximum rate of 5% and will be exempt in certain circumstances. NA (except for certain business income, when tax on the income for the first half-year must be paid by 30 September each year) Value-added tax (VAT) rates Standard VAT rate (%) 5% for royalties for any patent, design or model, plan, secret formula, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience; 7.5% for technical fees; 15% for all other royalties. Corporate taxpayers are required to file a tax return annually. through protocol or renegotiation). Eswatini (Last reviewed 20 June 2022) NA: NA: Fiji (Last reviewed 19 July 2022) 10: 10: Stamp duty exemption on instruments of transfer of real property, or lease of land, or building used for the purpose of carrying on a qualifying activity (executed on or after 13 June 2008 but not later than 31 December 2022). MSC Malaysia companies are eligible for incentives, which include the following: Companies that undertake any of the following green technology projects will be eligible for an ITA of 100% of QCE against 70% statutory income for QCE incurred for three years (applications to be received by 31 December 2023): Companies that provide services, such as advisory, design, feasibility study, testing, and commissioning, in the following areas will be eligible for income tax exemption of 70% of statutory income for three years (applications to be received by 31 December 2023): Companies engaged in solar leasing are eligible for income tax exemption of 70% of statutory income for five or ten years based on the energy production capacity (applications to be received by 31 December 2023). A new tax convention between Canada and the State of Israel is effective as of 1 January 2017 (in force since 21 December 2016). Companies that purchase green technology assets listed on the MyHijau directory will be eligible for an ITA of 100% of QCE incurred from 25 October 2013 to 31 December 2023, to be set off against 70% of statutory income (applications to be received by 31 December 2023). Poland Namibia High-technology companies engaged in areas of new and emerging technologies. 5% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% of the gross amount of the dividends if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends and the dividends are paid out of profits that, by virtue of law of the state in which the payer is a resident, are exempt from corporate tax or subject to corporate tax at a rate that is lower than the normal rate in that state; 15% of the gross amount of the dividends in all other cases. 10% for interest derived from a loan of whatever kind granted by a bank, savings institution, or insurance company or the like. For machinery and equipment used for the purpose of industrial production activities, the 5% VAT that used to be imposed is removed as per the newly issued updates in the law no.3 as of January 2022 (amending some articles in the VATLaw), and the VAT that is due on such machinerywould be put on hold for one year from the importationdate, this year would be extended for further one year and so on. WHT of 10% is payable on the interest accruing or paid to a non-resident. Tax returns. Transportation income is any income derived from, or in connection with, (i) the use (or hiring or leasing for use) of a vessel or aircraft, or (ii) the performance of services directly related to the use of a vessel or aircraft. OECD Tax Interest received by a financial institution is tax exempt. The real estate tax rate is 10% of the rental value, and the calculation of the rental value differs for residential units and non-residential units. Stamp duty is enacted on the disposal of shares as per the publication number 24 in the official gazette published on 19 June 2017. This site uses cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, and help us understand your interests and enhance the site. Set out below is a listing of WHT rates for dividends, interest, and royalties under domestic tax law and pursuant to tax treaties in force. Foreign exchange administration flexibilities and approval of expatriate positions based on stated policies. More specifically. Visit our. The current standard rate is 25%, food and drink is 15%, and movie theater tickets and public transportation 8%. Use local services (banking, finance, and insurance) and infrastructure (local ports and airports) in its operations. By continuing to browse this site you agree to the use of cookies. The BMT is a 15% minimum tax on adjusted financial statement income (AFSI). 5% for interest paid in connection with the sale on credit of any industrial, commercial, or scientific equipment, sale on credit of any merchandise by one enterprise to another enterprise, or on any loan of whatever kind granted by a bank. Intellectual property income (as defined) is excluded from the incentive. Accelerated tax depreciation allowances for approved energy efficient equipment. ITA is granted on 60% qualifying capital expenditure incurred for a period of five years and is utilised against 70% of the statutory income, while the 30% balance is taxed at the prevailing CIT rate. Dividends paid from a foreign resident company received via an Israeli payer (e.g. Corporate - Tax credits and incentives Last reviewed - 13 June 2022. The above rate applies to all types of business activities except for oil exploration companies, whose profits are taxed at 40.55%. Note: If new commercial connections to the electricity grid were not issued in a given year, or if electricity is not provided during that period, the economy receives a no practice mark on the procedures, time and cost indicators.A no practice economy receives a score of 0 on the reliability of supply and transparency of tariff index regardless of the regulatory practices that RPGT and stamp duty exemptions on disposal/transfer of real property to an REIT/PTF. PS is given by way of exemption from CIT on 70% of the statutory income for five years and the remaining 30% is taxed at the prevailing CIT rate. By submitting your email address, you acknowledge that you have read the Privacy Statement and that you consent to our processing data in accordance with the Privacy Statement. For royalties in respect of cinematograph or television films, tax may be imposed in Israel, but not to exceed tax at the rate applicable to companies on 15% of the gross amount of the royalty. When the beneficiaries live in a country with a privileged tax regime, the applicable rate is 10%. green technology, educational services, healthcare services, creative industries, financial advisory and consulting services, logistics services, tourism) in that specified region. Mergers and acquisitions allowance The mergers and acquisitions allowance allows a write-off of 25% of the value of qualifying mergers or acquisitions deals executed between 1 April 2015 and 31 December 2025. At a rate that is 50% of the rate that would have been imposed but for this provision but not to exceed 12.5% and not less than 7.5%. Single deduction for prescribed relocation costs incurred by TRX Marquee status companies for relocation that takes place not later than 31 December 2025. If the sale and purchase transaction involves 33% or more of the value or the number of shares or voting rights in a resident company, or. Such funds must be approved by the Securities Commission. Income tax exemption on statutory income for ten years or income tax exemption equivalent to 100% of QCE incurred for 5 years (applications receivedby 31 December 2022). 5% if the beneficial owner is a company (other than a real estate investment fund that is a resident of Israel) that directly holds at least 10% of the voting power in the company paying the dividends throughout a 365-day period that includes the day of payment of the dividend (for the purposes of computing that period, no account shall be taken of changes of ownership that would directly result from a corporate reorganisation, such as a merger or divisive reorganisation, of the company that holds the shares or that pays the dividend). Egypt is embarking on implementing a new comprehensive health insurance system, starting from 2019. Where incentives are given by way of allowances, any unutilised allowances may be carried forward indefinitely to be utilised against future statutory income, except for certain incentives, such as reinvestment allowance and investment allowance for approved service projects, where a seven-year limitation applies. The global minimum tax agreement does not seek to eliminate tax competition, but puts multilaterally agreed limitations on it, and will see countries collect around USD 150 billion in new revenues annually. as of 1 July 2017; previously 13%). interest, dividends, and royalties) not effectively connected with a non-US corporations business continues to be taxed on a gross basis at 30%. Sweden Developing country revenue gains are expected to be greater than those in more advanced economies, as a proportion of existing revenues. 2017 - 2022 PwC. A 25% credit on qualifying R&D expenditures; total effective tax deduction of 37.5%. The tax rate is 25%. PS of 70% of statutory income for five years for income from qualifying activities in MWC. Your message was not sent. Portugal PwC Sweden. A principal hub is a locally incorporated company that uses Malaysia as a base for conducting its regional and global businesses and operations through management, control, and support of key functions, such as management of risk, strategic decisions, finance, and human resources. effectively connected income or ECI). Further benefits will also arise from the stabilisation of the international tax system and the increased tax certainty for taxpayers and tax administrations. Beginning from 1 October 2019, corporate taxpayers are required to file and pay the national local corporate tax at a fixed rate of 10.3% of their corporate tax liabilities. Tax deduction given for consultancy, legal, and valuation service fees incurred on the establishment of an REIT. Corporate - Significant developments; Corporate - Corporate residence; Print Current Page; Print Corporate Tax Summary; Print Individual Tax Summary; Contacts In general, a taxpayer is an applicable corporation if its average annual AFSI over a three-tax year period exceeds $1 billion. 5% where in connection with the sale on credit of any industrial, commercial, or scientific equipment, or sale on credit of any merchandise by one enterprise to another enterprise, or on any loan of whatever kind granted by a bank loans made by banks; 10% in all other cases. Such tax is assessed based on the rental value of the land and building, and these value assessments are set by the committees, after approval of the Minister or whomever the Minister delegates, and published in the Official Journal. A real estate tax, which is based on the value of the property or rental received, is assessed annually on land and buildings used for business purpose or leased. Companies providing technical and vocational training, and private higher education institutions providing qualifying. Saudi Arabia ITA of 60% on QCE incurred within five years, against 70% of statutory income. Statutory corporate income tax rates; Published: OECD member countries April 2021, inclusive framework data July 2021 A resident company undertaking a project approved by the Minister of Finance in the transportation, communications, utilities, and services subsectors may enjoy the following incentives: A resident company engaged in manufacturing or agriculture that exports manufactured products, agricultural produce, or services is entitled to allowances between 10% and 100% of value of increased exports (subject to satisfying prescribed conditions), which is deductible at up to 70% of statutory income. The IRA enacted a new corporate AMT, effective for tax years beginning after 2022, based on financial statement income (book minimum tax, or BMT). 5% for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematograph films or films or tapes used for radio or television broadcasting. Tax exemption of 70% of statutory income for five years, or ITA of 60% of QCE incurred within five years to be set off against 70% statutory income, for new companies. 0% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 5% rate in all other cases. A WHT rate of 47% applies in the case of a substantial shareholder (in general, a shareholder that holds 10% or more of rights of the company). For high labour-intensive industries (rubber products, plastics, wood, furniture, and textiles industries): 200% automation capital allowance on first MYR 4 million QCE(for years of assessment 2015 to 2023). For passive income from the leasing of equipment, and not in the Royalty article, it is covered by the Other Income article, if any. The tax was 20% of alternative minimum taxable income (AMTI) in excess of a USD 40,000 exemption amount (subject to a phase-out). Organisation for Economic Co-operation and Development (OECD), Interest paid on a bond to a shareholder who holds less than 10% of the rights of the company is generally taxed at a rate of 35%. 5% for copyright royalties for literary, artistic, or scientific work (excluding cinematograph films) or for the use of, or the right to use, industrial, commercial, or scientific equipment or road-transport vehicles. Prior to enactment of P.L. Tax on corporate income is imposed at a flat rate of 17%. Error! 2017 - 2022 PwC. The following incentives are given to encourage investment and relocation of manufacturing or servicesoperations into Malaysia: Applications must be received by 31 December 2022. Remittance tax. Based on the law, resident investors trading in or holding Egyptian shares/securities unlisted on the EGXand whether buyers or sellers should be subject to 0.05% stamp tax on the total proceeds realised without deducting any costs (for the transactions involvingless than 33% of a company's shares). The ordinary corporate tax is deductible in the basis for the calculation of the resource rent tax, resulting in an overall marginal tax rate of 59%. 115-97 repealed the corporate AMT effective for tax years beginning after 31 December 2017 and provided a mechanism for prior-year corporate AMT credits to be refunded by the end of 2021. If the sale and purchase transaction involves 33% or more of the assets or the liabilities of a resident company by another resident company in return of shares in the acquiring company. Special surcharges and taxes. Namibian companies, however, are taxed on interest at the corporate tax rate. Employment must have commenced between 24 October 2009 and 31 December 2020. Upon filing the online VAT return, taxpayers should pay the VAT amount due through the regular bank transfers and then enter the details of the payment on the ETAs website to finalise the VAT e-filing process. Information reportingof the US-source payments is always required even if no withholding applies. Countries are aiming to sign a multilateral convention during 2022, with effective implementation in 2023. Individuals (whether resident or non-resident), body of persons, or other unincorporated persons, None (income to be included in annual tax return). 5% for royalties for literary, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio, or television broadcasting. Specific percentages of deductions are provided by the law to account for all the expenses incurred by the taxpayer, including maintenance costs. Income tax exemption for ten years in respect of income derived from: Income tax exemption on statutory income for ten years, from the provision of park management services in the industrial park or free zones (applications receivedby 31 December 2022). There is no local or provincial income tax applicable to corporates in Sri Lanka. Singapore 5% for industrial, commercial, and scientific equipment royalties. It is an applicable corporation if (1) the three-year average AFSI of all members of the group exceeds $1 billion and (2) the three-year average AFSI of US members of the group (and disregarded entities owned by members of the group), US trades or business of foreign group members that are not subsidiaries of US members, and foreign subsidiaries of US members exceeds $100 million. professional services, construction services, processed potatoes), and it should only be imposed once more if there was a change in the product status. 7% for interest paid on any loan of whatever kind granted by a bank. In addition, anew article was recently introduced to the Real Estate Tax Law, allowing by means of a decision from the Egyptian Cabinet, real estate tax exemption for the real estate actually exploited in the production and services activities stated by the Egyptian Cabinet, provided that the decision includes the below, for each production or service activity: There are two distinct types of stamp tax, which are imposed on legal documents, deeds, banking transactions, company formation, insurance premiums, and other transactions, as follows: An annual proportional stamp tax at the rate of 0.4%, shared by the bank and the client, is imposed on a bank's loans. MSC Malaysia status is awarded to both local and foreign companies that develop or use multimedia technologies to produce or enhance their products and services as well as for process development. Fees, ranging between EGP 1,000 and EGP 15,000, paid by hospitals, medical clinics, treatment centres, pharmacies, and pharmaceutical companies to subscribe to the new health insurance system. Except in certain circumstances, a dividend paid by a domestic corporation to a foreign person is U.S.-source income that is subject to U.S. tax at the statutory rate. In November 2020, the ETA started applying the e-invoicing system gradually in phases. disposal of any right over any land, or disposal of a building, or rights over building, or part of building, or. More specifically,P.L. 0% if to a pension fund or if paid on publicly traded corporate bonds or in respect of a loan, debt-claim, or credit guaranteed or insured by an institution for insurance or financing of international trade transactions that is wholly owned by Israel. For Sweden, to be entitled to the exemption, the pension fund must not sell or make a contract to sell the holding from which the dividend is derived within two months of the date the pension fund acquired the holding. This stamp tax is due on a quarterly basis on the beginning balance of each quarter of credit facilities and loans and advances provided by Egyptian banks or branches of foreign banks during the financial year in addition to the amounts utilised within the quarter. Generally, this limitation applies to interest, royalties, and dividends. Additional 50% tax deduction of rental payment incurred by TRX Marquee status companies for buildings used for business in TRX. P.L. 0% for copyright royalties for literary, artistic or scientific work (excluding cinematograph films). Under Israeli domestic tax law, WHT on payments of Israeli-source income is generally deducted at the corporate tax rate from all income remittances abroad, unless a tax certificate is obtained from the ITA authorising withholding-exempt remittances or a reduced rate of tax pursuant to an applicable tax treaty. Corporate income tax (CIT) rates. The current corporate income tax (CIT) rate is comprised of an 18.5% normal tax and a graduated surtax (computed on the 'surtax net income'). Where profits of a non-resident company are remitted in a tax year, a remittance tax of 14% of the remittances is payable (prior to 1 April 2018, it was at 10%). Further information on the continuing international tax reform negotiations is also available at: https://oe.cd/bepsaction1. 15% if the beneficial owner is a company (other than a partnership) that directly or indirectly holds at least 10% of the voting power of the company paying the dividends. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. A qualified knowledge worker is taxed at the rate of 15% on chargeable income from employment with a designated company engaged in a qualified activity (e.g. Please see www.pwc.com/structure for further details. A corporation that is a member of a foreign-parented multinational group must apply a two-part test. Detailed description of taxes on corporate income in Saudi Arabia Worldwide Tax Summaries. The rate of tax is 2% of the selling price of the building. The BEAT is imposed to the extent that 10% (5% for 2018) of the taxpayers modified taxable income (generally, US taxable income determined without regard to any base-eroding tax benefit or the base-erosion percentage of the NOL deduction) exceeds the taxpayers regular tax liability net of most tax credits. Loans from other establishments are not subject to this tax. Netherlands Numerous adjustments are made to financial statement income to determine AFSI, and these rules also differ for purely domestic corporations and corporations that are part of a consolidated group with a foreign parent. Also, Customs tax amounting to (1%) of the stipulated customs tax on the date of the temporary release shall be collected for every month or part thereof with a maximum of (10%) annually for equipment, new and renewable energy components and their spare parts. Print Corporate Tax Summary; Print Individual Tax Summary; Contacts News Print Search Sweden contacts Sweden contacts. 10% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends. Standard enterprise tax (and local corporate special tax) US tax reform legislation enacted on 22 December 2017 (P.L. 0% for copyright royalties for literary, artistic, or scientific work (excluding cinematograph films or tapes for television or broadcasting). This is the rate for royalties for the use of, or the right to use, industrial, commercial, and scientific equipment. Pillar One will ensure a fairer distribution of profits and taxing rights among countries with respect to the largest and most profitable multinational enterprises. a This table was initially adapted from Table 1 of the IRS Tax Treaty Tables, available at www.irs.gov/individuals/international-taxpayers/tax-treaty-tables. 5% for industrial, commercial, or scientific equipment royalties. A new tax treaty between Israel and Germany is effective as of 1 January 2017 (in force since 9 May 2016). foreign tax credit (FTC), which is available to an applicable corporation that claims an FTC for the tax year. The proposal is currently awaiting approval by the Swedish Parliament. Percentage or proportionate stamp tax is levied based on the value and natureof the transactions. all tax items [e.g. All rights reserved. Other industries: 200% automation capital allowance on first MYR 2 million QCE(for years of assessment 2015 to 2023). Please see www.pwc.com/structure for further details. 10% for interest received by any financial institution (including an insurance company). The category also includes certain paymentsby expatriated entitiessubject tothe anti-inversion rules of Section 7874. An exception applies if the employees is working in Sweden for less than 15 days in a row and less than 45 days in total during a calendar year. Error! Local income taxes. Zakat is charged on the companys Zakat base at 2.5%. 0% if to a pension fund or if paid on publicly traded corporate bonds or if the company paying the funds or the beneficial owner is one of the contracting states or one of their central banks, political subdivisions, or local authorities. Portugal Please contact for general WWTS inquiries and website support. S corporations are taxed in a manner similar, but not identical, to partnerships (i.e. This site uses cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, and help us understand your interests and enhance the site. Under the Egyptian VAT law no. Certain US-source income (e.g. The standard rate is applicable on all goods and services. On the other hand, in case any of the below-mentioned conditions are met, then the rate of the stamp duty to be imposed in such case should be 0.3%: In both cases above, the buyer and seller (i.e. 0% if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends; 15% in all other cases. Please contact for general WWTS inquiries and website support. Working with over 100 countries, the OECD is a global policy forum that promotes policies to preserve individual liberty and improve the economic and social well-being of people around the world. The foreign expatriates residing in Egypt may also be allowed to subscribe in the new health insurance system, according to certain conditions and in case of reciprocal treatment by their home country. The exemption applies only to interest on credits, loans, and other indebtedness connected with the financing of trade between the United States and the CIS member. 5% in connection with the sale on credit of any industrial, commercial, or scientific equipment, or in connection with the sale on credit of any merchandise by one enterprise to another enterprise, or on any loan granted by a financial institution. (see footnote 20), if certain additional requirements are met, www.irs.gov/individuals/international-taxpayers/tax-treaty-tables, Dividends paid by US corporations in general (1), Dividends qualifying for direct dividend rate (1, 2), Commonwealth of Independent States (CIS) (7), Dividends paid by a domestic subsidiary to a foreign parent corporation that has the required percentage of stock ownership are subject to a reduced rate, usually 5%, and, under some treaties. Under Pillar One, taxing rights on more than USD 125 billion of profit are expected to be reallocated to market jurisdictions each year. These five are (1) industrial equipment royalties, (2) know-how/other industrial royalties, (3) patent royalties, (4) motion picture and television royalties, and (5) copyright royalties. 10% if the recipient holds at least 25% of the capital of the company paying the dividends. Protection of intellectual property and cyber laws. It is important to mention that any non-compliance with the new health insurance system may result in financial or imprisonment penalties. 5% if the beneficial owner is a company that owns at least 25% of the voting shares of the company paying the dividends during the period of six months immediately before the end of the accounting period for which the distribution of profits takes place. 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