EUS EXECUTIVE UPDATING SERVICE Updating Acts, Ordinances, Statutory Rules & Orders (SROs.) etc.

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1 EUS EXECUTIVE UPDATING SERVICE Updating Acts, Ordinances, Statutory Rules & Orders (SROs.) etc. III-H 11/21 NAZIMABAD Ph: (92-21) For EUS Clients Use Only EUS UPDATE ADVANCE TAX PAID BY THE TAXPAYER Section 147 of the Income Tax Ordinance, 2001 (XLIX of 2001) Read with EUS Update Advance Tax Regime (ATR) 1 1. ADVANCE TAX PAID BY THE TAXPAYER Extract from Technical Measures [FBR Salient Features for Budget (Income Tax)]. In order to streamline accounting of Advance Tax payments, certain amendments are proposed in section 147 of the Ordinance, so that quarterly advance tax payments are paid by 25th of last month, as compared to earlier requirement of such payments by 15th of every month after the end of a quarter. ADVANCE TAX PAID BY THE TAXPAYER [Section 147] Through amendments in section 147 of the Income Tax Ordinance, 2001 following changes have been brought in the ATR: (i) (ii) (iii) (iv) (v) Exemption on capital gains available for the purposes of this section has been omitted [clause (a) of sub-section (1) has been omitted]; Association of Persons (AOPs), with annual turnover of Rs. 50 Million and above, has also been made liable to pay advance tax under section 147 [sub-sections (2) & (4) amended]; Basic income threshold for the purposes of payment of advance tax under this section has been raised from Rs. 200,000 to Rs. 500,000 [subsection (2) amended]; In order to ensure timely payment of advance tax during the relevant quarter, sub-section (5A) has been substituted to prescribe the amended dates for payment of quarterly advance tax; and Rates of quarterly adjustable advance tax on capital gains from disposal/redemption of securities Not applicable to individual investors, provided under newly inserted sub-section (5B) of section of section 147.

2 Advance tax paid by the taxpayer. (1) Subject to sub-section (2), every taxpayer 2 [whose income was charged to tax for the latest tax year under this Ordinance or latest assessment year under the repealed Ordinance] other than 3 [Extract from Para 13 of the FBR Finance Act, 2010 Explanatory Circular No. 10/2010 (Income Tax) dated /C.No.ITP/B /EC-e-Dox # R signed by the Secretary (Income Tax Policy), Mr. Sajid Nazir Malik]. 2. CHARGEABILITY - Substituted for the words who derives or expects to derive income chargeable to tax under this Ordinance in a tax year by the Finance Act, ADVANCE TAX Clarification [Extract from para 31 of FBR IT Cir. 03 dated ]: FINANCE ACT, 2009 EXPLANATION REGARDING IMPORTANT AMENDMENTS MADE IN THE INCOME TAX ORDINANCE, 2001 PAYMENT OF ADVANCE TAX (Section 147): In case of a company, the mode of determining advance tax liability u/s 147 has been amended and now it is payable on turnover basis as per formula mentioned in sub-section (4) of section 147. Since the actual amount of turnover will not be available on the due date prescribed under sub-section (5), therefore, a new sub-section (5A) has been inserted whereby the schedule for advance tax payment has been given. The taxpayer shall also be required to take into consideration tax u/s 113 while computing tax liability u/s 147. Further, advance tax is also payable, in the absence of last assessed income or declared turnover on the basis of tax liability under section 113. Example-I A is the taxpayer s turnover for the quarter; Rs. 1,000,000 B is the tax assessed to the taxpayer for the Rs. 100,000 latest tax year; C is the taxpayer s turnover for the latest Rs. 4,000,000 tax year; and D is the tax paid in the quarter for which a Rs. Nil tax credit is allowed under section 168, other than tax deducted under section 155 Tax payable for the quarter [(A x B/C) D] Rs. 25,000 Example-II A is the taxpayer s turnover for the quarter; Rs. 1,000,000 B is the tax assessed to the taxpayer for the Rs. 100,000 latest tax year;

3 3 4 [(a)] (b) income chargeable to tax under 5 [sections 5, 6 and 7]; 6 [(ba) income chargeable to tax under section 7 [15];] (c) income subject to deduction of tax at source under 8 [section 149]; 9 [and] C is the taxpayer s turnover for the latest Rs. 4,000,000 tax year; and D is the tax paid in the quarter for which a Rs. 15,000 tax credit is allowed under section 168, other than tax deducted under section 155 Tax payable for the quarter [(A x B/C) D] Rs. 10, CAPITAL GAINS/ATR Following clause (a) omitted by the Finance Act, 2010 (XVI of 2010): (a) income chargeable to tax under the head Capital Gains ; Notes on Clauses of Finance Bill Seeks to include persons earning income from capital gains in advance tax regime. 5. CHARGE OF TAX Chapter II (sections 4 to 8) of the Income Tax Ordinance, 2001 discussed Charge of Tax through following sections: 4. Tax on taxable income 5. Tax on dividends 6. Tax on certain payments to non-residents (royalties) 7. Tax on shipping and air transport income of a non-resident person 8. General provisions relating to taxes imposed under sections 5, 6 and INCOME FROM PROPERTY Clause (ba) inserted by the Finance Ordinance, TAX ON TAXABLE INCOME Chapter III (containing Parts I-X/sections 9 to 65) of the Income Tax Ordinance, 2001 discussed Tax on taxable income, where Part-III (Head of Income: Income from Property) contains following sections: 15. Income from property, and 16. Non-adjustable amounts received in relation to buildings. 8. PROCEDURE Chapter X (containing Parts I-XIII/sections 114 to 206A) of the Income Tax Ordinance, 2001 discussed Procedure. Part-V (Advance Tax and Deduction of Tax at Source) contains Divisions I to IV/sections 147 to 169. Division III (Deduction of tax at source) contents following sections, where section 149 deals in salary :

4 4 10 [(ca)] (d) income from which tax has been collected under 11 [Division II or deducted under Division III] 12 [or deducted or collected 149. Salary 150. Dividends 151. Profit on debt 152. Payments to non-residents 153. Payments for goods and services 153A. Payments to non-residents media persons 154. Exports 155. Income from property 156. Prizes and winnings 156A. Petroleum products 156B. Withdrawal of balance under Pension Fund 158. Time of deduction of tax. Read under EUS Update WHT Provisions. 9. Substituted for the word or by the Finance Act, 2009 (I of 2009). 10. BROKERAGE & COMMISSION, AND TAX COLLECTED BY STOCK EXCHANGE Following clause (ca), duly inserted by the Finance Act, 2006, omitted by the Finance Act, 2009 (I of 2009): (ca) income chargeable to tax under section 233 and clauses (a) and (b) of sub-section (1) of section 233A; 11. PROCEDURE Chapter X (containing Parts I-XIII/sections 114 to 206A) of the Income Tax Ordinance, 2001 discussed Procedure. Part-V (Advance Tax and Deduction of Tax at Source) contains Divisions I to IV/sections 147 to 169, where Divisions II & III contain following sections: Division II Advance tax paid to a Collection Agent 148. Imports Division III Deduction of tax at source 149. Salary 150. Dividends 151. Profit on debt 152. Payments to non-residents 153. Payments for goods and services 153A. Payments to non-residents media persons 154. Exports 155. Income from property 156. Prizes and winnings 156A. Petroleum products

5 5 under Chapter XII] and for which no tax credit is allowed as a result of 13 [sub-section (3) of section 168], shall be liable to pay advance tax for the year in accordance with this section. (2) This section does not apply to an individual 14 [ ] where the individual s 15 [ ] latest assessed taxable income excluding income referred 156B. Withdrawal of balance under Pension Fund 158. Time of deduction of tax. Read under EUS Update WHT Provisions. 12. TRANSITIONAL ADVANCE TAX PROVISIONS - Words etc. inserted by the Finance Act, 2009 (I of 2009). Chapter XII of the Income Tax Ordinance, 2001 discussed the Transitional Advance Tax Provisions through following sections: 231A. Cash withdrawal from a bank 231AA. Advance tax on transactions in bank 231B. Advance tax on private motor vehicles 233. Brokerage and commission 233A. Collection of tax by a stock exchange registered in Pakistan 234. Tax on motor vehicles 234A. CNG stations 235. Electricity consumption 236. Telephone users 236A. Advance tax at the time of sale by auction. 236B. Advance tax on purchase of air ticket Read under EUS Update WHT Provisions. 13. Section 168 deals in Tax collected or deducted as a final tax. Read under EUS Update WHT Provisions. 14. AOP/ATR The words or association of persons omitted by the Finance Act, 2010 (XVI of 2010). Earlier said words were inserted w.e.f by the Finance Act, Notes on Clauses of Finance Bill 2010 Seeks to include AOPs in advance tax regime. 15. AOP/ATR The words or association of persons omitted by the Finance Act, 2010 (XVI of 2010). Earlier said words were inserted w.e.f by the Finance Act, Notes on Clauses of Finance Bill 2010 Seeks to include AOPs in advance tax regime. Editorial Correction. The words association of persons were substituted for associations of persons by the Finance Act, 2005.

6 6 to in clauses (a), (b), 16 [(ba)], (c) and (d) of sub-section (1) is less than 17 [ 18 [five] hundred thousand] rupees. 19 [(3)] 20 [(4) Where the taxpayer is 21 [an association of persons or] a company, the amount of advance tax due for a quarter shall be computed according to the following formula, namely: 16. INCOME FROM PROPERTY Clause (ba) reference inserted by the Finance Ordinance, SPECIFIC INCOME THRESHOLD Substituted for the words one hundred and fifty thousand by the Finance Act, INDIVIDUALS LIMIT FOR ATR - Substituted for the word two by the Finance Act, 2010 (XVI of 2010). Notes on Clauses of Finance Bill Seeks to facilitate individuals by enhancing the limit for advance tax from Rs. 200, QUARTERS/PERIOD Following sub-section (3) omitted w.e.f by the Finance Act, 2004: (3) Advance tax shall be payable by a taxpayer in respect of the following periods, namely: (a) 1 st of July to 30 th September (referred to as the September quarter ); (b) 1 st October to 31 st December (referred to as the December quarter ); (c) 1 st January to 31 st March (referred to as the March quarter ); and (d) 1 st April to 30 th June (referred to as the June quarter ). 20. COMPANY ADVANCE TAX FORMULA Sub-section (4) substituted for the following by the Finance Act, 2009 (I of 2009): (4) where the taxpayer is a company, the amount of advance tax due for a quarter shall be computed according to the following formula, namely: Where A (A/4) B is the tax assessed to the taxpayer for the latest tax year or latest assessment year under the repealed Ordinance; and

7 7 (A x B/C) D Where A B C D is the taxpayer s turnover for the quarter; is the tax assessed to the taxpayer for the latest tax year; is the taxpayer s turnover for the latest tax year; and is the tax paid in the quarter for which a tax credit is allowed under 22 [section 168], other than tax deducted under 23 [section 155].] B is the tax paid in the quarter for which a tax credit is allowed under section 168, other than tax deducted under section 149 or 155. EXTRACT FROM NOTES ON CLAUSES OF FINANCE BILL, 2009 Seeks to substitute the basis of payment of advance tax from assessment to turnover in the case of company and AOP [EUS Note. AOP excluded in final amendment by the Finance Act, 2009 (I of 2009)]. Earlier sub-section (4) was substituted w.e.f by Finance Act, ATR/AOPs - After the word is occurring for the first time, the words an association of persons or inserted by the Finance Act, 2010 (XVI of 2010). Notes on Clauses of Finance Bill Seeks to make a consequential amendment for advance tax on AOPs. 22. Section 168 deals in Tax collected or deducted as a final tax. Read under EUS Update WHT Provisions. 23. INCOME FROM PROPERTY - Chapter X (containing Parts I-XIII/sections 114 to 206A) of the Income Tax Ordinance, 2001 discussed Procedure. Part-V (Advance Tax and Deduction of Tax at Source) contains Divisions I to IV/sections 147 to 169. Division III contents following sections, where section 155 deals in income from property : 149. Salary 150. Dividends 151. Profit on debt 152. Payments to non-residents 153. Payments for goods and services 153A. Payments to non-residents media persons 154. Exports 155. Income from property

8 8 24 [(4A) Any taxpayer who is required to make payment of advance tax in accordance with sub-section (4), shall estimate the tax payable by him for the relevant tax year, at any time before the last instalment is due. In case the tax payable is likely to be more than the amount he is required to pay under sub-section (4), the taxpayer shall furnish to the Commissioner an estimate of the amount of tax payable by him and thereafter pay such amount after making adjustment for the amount (if any) already paid in terms of subsection (4).] 25 [(4AA) Tax liability under 26 [section 113] shall also be taken into account while working out payment of advance tax liability under this section.] 27 [(4B) Where the taxpayer is an individual 28 [ ] having latest assessed income of 29 [five] hundred thousand rupees or more as determined 156. Prizes and winnings 156A. Petroleum products 156B. Withdrawal of balance under Pension Fund 158. Time of deduction of tax. Read under EUS Update WHT Provisions. 24. ESTIMATING Existing sub-section (4A) (earlier inserted by the Finance Act, 2003), re-numbered as sub-section (4B) and before sub-section (4B), renumbered as aforesaid, the above-mentioned new sub-section (4A) inserted vide Finance Act, MINIMUM TAX Sub-section (4AA) newly inserted by the FA, EXTRACT FROM NOTES ON CLAUSES OF FINANCE BILL, 2009 Seeks to allow the credit of taxes paid under another section. Earlier similar/following sub-section (4AA) (duly inserted by the Finance Act, 2007), omitted by the Finance Act, 2008: (4AA) Tax liability under section 113 shall also be taken into account while working out payment of advance tax liability under this section. Extract from Notes on Clauses of Finance Bill, 2008 Income Tax Ordinance, 2001 Seeks to omit charge of minimum tax on turnover for the purpose of advance tax and to omit payment of turnover tax for the purpose of advance tax. 26. MINIMUM TAX Read under EUS Update Minimum Tax Exemptions.

9 9 under sub-section (2), the amount of advance tax due for a quarter shall be computed according to the following formula, namely: Where (A/4) B A B is the tax assessed to the taxpayer for the latest tax year or latest assessment year under the repealed Ordinance; and is the tax paid in the quarter for which a tax credit is allowed under 30 [section 168], other than tax deducted under 31 [section 149 or 155]. ] 27. COMPUTATION OF QUARTERLY ADVANCE TAX Sub-section (4B) inserted by the Finance Act, 2003 [as sub-section (4A)] and re-numbered as subsection (4B) by the Finance Act, AOP/ATR The words or association of persons omitted by the Finance Act, 2010 (XVI of 2010). Earlier said words were inserted by the Finance Act, Notes on Clauses of Finance Bill 2010 Seeks to include AOPs in advance tax regime. 29. INDIVIDUALS LIMIT FOR ATR - Substituted for the word two by the Finance Act, 2010 (XVI of 2010). Notes on Clauses of Finance Bill Seeks to facilitate individuals by enhancing the limit for advance tax from Rs. 200, CREDIT FOR TAX COLLECTED OR DEDUCTED Updated version of above-referred section 168 available here in this document. 31. SALARY INCOME & INCOME FROM PROPERTY - Chapter X (containing Parts I-XIII/sections 114 to 206A) of the Income Tax Ordinance, 2001 discussed Procedure. Part-V (Advance Tax and Deduction of Tax at Source) contains Divisions I to IV/sections 147 to 169. Division III contents following sections, where section 149 deals in salary and 155 in income from property : 149. Salary 150. Dividends 151. Profit on debt 152. Payments to non-residents 153. Payments for goods and services 153A. Payments to non-residents media persons 154. Exports 155. Income from property 156. Prizes and winnings

10 10 (5) Advance tax is payable by 32 [an individual 33 [ ] ] to the Commissioner (a) (b) (c) (d) in respect of the September quarter, on or 34 [before] the 35 [15 th day of September]; in respect of the December quarter, on or before the 36 [15 th day of December]; in respect of the March quarter, on or before the 37 [15 th day of March]; and in respect of the June quarter, on or before the 38 [15 th day of June]. 39 [(5A) Advance tax shall be payable by an association of persons or a company to the Commissioner 156A. Petroleum products 156B. Withdrawal of balance under Pension Fund 158. Time of deduction of tax. Read under EUS Update WHT Provisions. 32. INDIVIDUAL OR AOP - Substituted for the words a taxpayer by the Finance Act, 2009 (I of 2009). EUS Note. This amendment was not proposed thru Finance Bill AOP/ATR The words or association of persons omitted by the Finance Act, 2010 (XVI of 2010). Notes on Clauses of Finance Bill 2010 Seeks to include AOPs in advance tax regime. 34. EDITORIAL CORRECTION Substituted for the word by by the Finance Act, QUARTERLY DUE DATE Substituted for 7 th day of October w.e.f by the Finance Act, QUARTERLY DUE DATE Substituted for 7 th day of January w.e.f by the Finance Act, QUARTERLY DUE DATE Substituted for 7 th day of April w.e.f by the Finance Act, QUARTERLY DUE DATE Substituted for 21 st day of June w.e.f by the Finance Act, 2004.

11 11 (a) (b) (c) (d) in respect of the September quarter, on or before the 25 th day of September; in respect of the December quarter, on or before the 25 th day of December; in respect of the March quarter, on or before the 25 th day of March; and in respect of the June quarter, on or before the 15 th day of June.] 40 [(5B) Adjustable advance tax on capital gain from sale of securities shall be chargeable as under, namely: 39. COMPANY ADVANCE TAX DUE DATES Sub-section (5A) [earlier inserted by the Finance Act, 2009 (I of 2009)/not proposed thru Finance Bill 2009] substituted for the following by the Finance Act, 2010 (XVI of 2010): (5A) Advance tax is payable by a company to the Commissioner (a) (b) (c) (d) in respect of the September quarter, on or before the 15th day of October; in respect of the December quarter, on or before the 15th day of January; in respect of the March quarter, on or before the 15 th day of April; and in respect of the June quarter, on or before the 15 th day of June Quarterly Payments Under ATR Notes on Clauses of Finance Bill 2010 Seeks to streamline the dates for quarterly payments under advance tax regime. 40. CAPITAL GAINS/ATR RATES & DATES - New sub-section (5B) inserted by the Finance Act, 2010 (XVI of 2010). Notes on Clauses of Finance Bill Seeks to provide rates of advance tax for person having income from capital gains. Seeks to provide dates of payment of advance tax for each quarter for persons earning income under the head capital gains. EUS Note. Certain different sub-section (5B) was proposed thru the Finance Bill 2010.

12 12 S. No. Period TABLE Rate of Advance Tax Where holding period of a security is less than six months. 2% of the capital gains derived during the quarter. 2. Where holding period of a security is more than six months but less than twelve months. 1.5% of the capital gains derived during the quarter: Provided that such advance tax shall be payable to the Commissioner within a period of 41 [twenty one] days after the close of each quarter: 42 Extract from Revenue Measures [FBR Salient Features for Budget (Income Tax)]. Tax on capital gains accruing on account of holdings of stocks/shares/securities for six-months or less is 10%, while holdings of stocks/shares/securities exceeding six-months is 7.5%. However no tax has been proposed on such capital gains arising held for a period exceeding 12 months. 41. CAPITAL GAIN ADVANCE TAX Substituted for the word seven by the Finance Act, EXTENSION IN DATE OF PAYMENT OF ADVANCE TAX The taxpayers are allowed to make payments of advance tax on capital gain on disposal of securities as required under section 147(5B) of the Income Tax Ordinance, 2001 for the 1 st & 2 nd quarter of the current financial year by as it has been noticed that in certain cases payment of aforesaid advance tax have not been made even by the extended date i.e [Extract of clarification vide FBR Circular No. 02 of 2011 (Income Tax) dated /C. No. 4(90)ITP/2007/34781-R (Subject: Extension in Date of Payment of Advance Tax on Capital Gain on Disposal of Securities) signed by the Secretary (Income Tax Policy), Mr. Sajid Nazir Malik Ph ]. Condonation of Time Limit - In exercise of the powers conferred under section 214A of the Income Tax Ordinance, 2001 (XLIX of 2001), the Federal Board of Revenue is pleased to extend the dates of quarterly payments of adjustable advance tax on capital gains, payable under sub-section (5B) of the section 147 of the income tax ordinance, 2001 as follows vide SRO. 35 (I)/2011 dated [C.No.4(90)ITP/2007 signed by the Member Policy (DT), Mr. Asrar Rauof]:

13 13 Provided further that the provisions of this sub-section shall not be applicable to individual investors.] 43 [(6) If any taxpayer who is required to make payment of advance tax under sub-section (1) estimates at any time before the last installment is due, that the tax payable by him for the relevant tax year is likely to be less than the amount he is required to pay under sub-section (1), the taxpayer may furnish to the Commissioner an estimate of the amount of the tax payable by him, and thereafter pay such estimated amount, as reduced by the amount, if any, already paid under sub-section (1), in equal installments on such dates as have not expired.] 44 [(6A) Notwithstanding anything contained in this section, where the taxpayer is a company or an association of persons, advance tax shall be First quarter ending on January 21, 2011 Second quarter ending on January 21, 2011 Third quarter ending on April 21, 2011 Fourth quarter ending on June 21, TURNOVER Sub-section (6) substituted for the following w.e.f by the Finance Act, 2004: (6) The turnover of a taxpayer for the period from 16 th to 30 th June of the June quarter shall be taken to be equal to the turnover for the period from 1 st to 15 th June of that quarter. 44. ADVANCE TAX ESTIMATES Sub-section (6A) (earlier inserted by the Finance Act, 2007 to take into account minimum tax paid for the purpose of estimating advance tax liability and to impose advance tax in first year of business of a company w.e.f ) substituted by the Finance Act, 2009 (I of 2009), and before substitution read as follows: (6A) Notwithstanding anything contained in this section, where the taxpayer is a company, advance tax shall be payable by it in the absence of last assessed income also. The taxpayer shall estimate the amount of advance tax payable on the basis of estimated quarterly accounting profit of the company and thereafter pay such amount after making adjustment for the amount (if any) already paid. 1 [ ] 1. Following clauses (a) & (b) omitted by the Finance Act, 2008: (a) (b) taking into account tax payable under section 113 as provided in subsection (4AA); making adjustment for the amount (if any) already paid.

14 14 payable by it in the absence of last assessed income or declared turnover also. The taxpayer shall estimate the amount of advance tax payable on the basis of quarterly turnover of the company or an association of persons, as the case may be, and thereafter pay such amount after, (a) (b) taking into account tax payable under 45 [section 113] as provided in sub-section (4AA); and making adjustment for the amount (if any) already paid.] (7) The provisions of this Ordinance shall apply to any advance tax due under this section as if the amount due were tax due under an assessment order. (8) A taxpayer who has paid advance tax under this section for a tax year shall be allowed a tax credit for that tax in computing the tax due by the taxpayer on the taxable income of the taxpayer for that year. (9) A tax credit allowed for advance tax paid under this section shall be applied in accordance with 46 [sub-section (3) of section 4]. EXTRACT FROM NOTES ON CLAUSES OF FINANCE BILL, 2009 Seeks to make payment in case of new business entities having no basis of previous assessment etc. and take adjustment of taxes paid under other sections. Extract from Salient Features for the Budget Presently, advance tax is payable in four quarterly instalments on the basis of last assessed income. It is proposed that far working out the advance tax liability the sales should also be taken in to account. Local Authorities. In view of certain amendments through the Finance Act, 2008 (I of 2008), local authorities are no more exempt from tax, and are liable to pay advance tax under section 147(6A) for Tax Year MINIMUM TAX - Updated version of above-referred section 113 read under EUS Income Tax Enclosures. 46. CHARGE OF TAX Sub-section (3) of section 4 of the Income Tax Ordinance, 2001 read as follows: 4. Tax on taxable income (3) Where a taxpayer is allowed more than one tax credit for a tax year, the credits shall be applied in the following order (a) any foreign tax credit allowed under section 103; then

15 15 (10) A tax credit or part of a tax credit allowed under this section for a tax year that is not able to be credited under sub-section (3) of section 4 for the year shall be refunded to the taxpayer in accordance with section [(11)] ** * ** (b) any tax credit allowed under Part X of Chapter III; and then (c) any tax credit allowed under sections 147 and TURNOVER Following sub-section (11) omitted w.e.f by the Finance Act, 2004: (11) In this section, turnover shall not include amounts referred to in clauses (a), (b) 1 [, (ba)], (c) and (d) of sub-section (1). 1. Reference of clause (ba) inserted by the Finance Act, Earlier it was provided that in making any assessment year beginning on or making any deduction or collection of tax for said year, the Ordinance shall have effect as if reference of clause (ba) was inserted vide SRO. 633 (I)/2002 dated , subsequently rescinded w.e.f by SRO. 608 (I)/2003 dated

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