‒ the Income Inclusion Rule (IIR), the Undertaxed Payment Rule (UTPR), the Subject to Tax Rule (STTR), the rule order, the calculation of the effective tax rate and the 2 OECD (2020), Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint: Inclusive Framework on The jurisdiction in which the Ultimate Parent Entity of an MNE Group is resident is a low tax jurisdiction (in which case there are no entities in the chain of ownership that can apply the Income Inclusion Rule). The second step would typically be necessary either because there are no group entities making direct payments which are resident in non-low tax jurisdictions which have implemented the Undertaxed Payment Rule, or because a cap has taken effect (discussed further below). The premise behind the Subject to Tax Rule is simple; namely, where a jurisdiction does not exercise its taxing rights over the receipt of certain payments to an adequate extent, the jurisdiction of the payer has the right to claw back those taxing rights, negating in part the relief it allows for the deduction of the payment for local tax purposes. The 7 Pillars of Inclusion were born. Tax-motivated inversions are another area where the Blueprint suggests further rules may need to be developed. a 50% loss restriction for local tax purposes in a jurisdiction with a high CIT rate) those losses would seemingly remain available for use in future period for GloBE purposes. The BEAT can potentially deny a deduction from a US corporation to a foreign related party if the payment gives rise to a deduction in the United States. Here you will find a range of issues that impact on safe, fair and inclusive sport. 0:07 [PDF Download] 10 Pillars … Developed by Play By the Rules (PBTR), the 7 Pillars of Inclusion represent the common areas of inclusion and provide a helpful framework to understand, shape and deliver actions so that your netball … On the other hand, certain entities or sectors may be excluded from the Subject to Tax Rule altogether. Accountability, for example, easily aligns with the emphasis that conservatives place on anticor-ruption and the rule of law. The Blueprint suggests that, where the source jurisdiction applies a top-up tax, the jurisdiction of residence may need to proportionately limit the exemption or credit that it provides under the relevant treaty such that the combined tax rate in the residence and source jurisdictions is equal to the agreed minimum rate. Take the Inclusion Action Survey Score some quick wins YOUR PATH TO INCLUSION SUCCESS! The 7 Pillars of Inclusion is a framework that can help your club embrace diversity and inclusion -... Jump to. Whereas Pillar One seeks to identify business models that are perceived to slip between the cracks of the existing international tax framework, Pillar Two is concerned about low tax outcomes. The discussion of the GILTI co-existence issue within the Blueprint signs off with a plea to the US in relation to the operation of its Base Erosion and Anti-abuse Tax (BEAT) which potentially looks like the makings of a political deal. Whilst losses arising within the GloBE regime are carried forward indefinitely, it is unclear the extent to which pre-regime losses would be admitted into the regime. Saved by Susan Sutherland. See more of Play by the Rules - making sport inclusive, safe and fair on Facebook. PBTR is a national initiative backed by Federal and State governments that promotes safe, fair and inclusive sport and provides an inclusive sport framework for sporting organisations from the … Administrators play a vital role in sport, particularly to reduce the potential for things to go wrong. A large portion of the Blueprint is dedicated to the computation of these ETRs. Sign Up. Clarissa Machado is a Latin America Tax Chair in Baker McKenzie Sao Paulo office. © 2016 Copyright Global Compliance News UG (haftungsbeschränkt). The Undertaxed Payment Rule applies two caps to protect against over taxation of subsidiary entities. This would include model legislation and guidance together with a multilateral review process. He has represented clients in all administrative phases of a controversy. The calculation of Covered Income under the Blueprint suggests groups would need to prepare separate computations for GloBE purposes; the starting point being the profit or loss positon for accounting purposes subject to a limited number of adjustments which are unlikely to fully align with local corporate income tax calculations. The 7 Pillars of Inclusion, created by Play By The Rules, looks at the common elements of inclusive practice across diverse population groups, including people with disabilities, people from multicultural backgrounds and Indigenous Australians. He counsels clients on US withholding tax and qualified intermediary rule, as well as money laundering avoidance legislation. Four Pillars of Inclusion. The ‘seven pillars of support for inclusive education’ outlined below are an attempt to provide structure for the range of literature and research which already exists in the field, and to promote further analysis and discussion of this area. Likewise, the usual tax advantaged investors with special status should also be carved out (Sovereign Wealth Funds, Pension Funds, Charities, etc.). Resources and tools to help sports be more inclusive and diverse. Lets Play Pillars of Eternity Part 70 - Court of the Penitents - Pillars of Eternity Gameplay. or. The quid pro quo of giving priority to GILTI would seem to be that the US switches off its BEAT tax in respect of payments that are subject to the Income Inclusion Rule. The Income Inclusion Rule is supported by the Undertaxed Payment Rule, which acts a backstop to deal with circumstances where the Income Inclusion Rule is unable, by itself, to bring low tax jurisdictions in line with the minimum rate. The 7 Pillars of Inclusion, created by Play By The Rules, looks at the common elements of inclusive practice across diverse population groups, including people with disabilities, people from multicultural backgrounds and Indigenous Australians. Pillars Of Eternity Review – Can a godlike wizard find all the pillars of ... Gamekult. The first step captures group entities which have made direct payments to entities resident in the low tax jurisdiction. Broadly, the aim is to arrive at a fractional calculation for each jurisdiction comprised of Covered Taxes as the numerator and Covered Income as the denominator. As a parent you should be aware of your clubs responsibilities. They play a crucial role in helping keep sport safe, fair and inclusive. International Tax: Pillar One – Overview of ‘the Blueprint’. He previously served as a Senior Advisor for Tax Reform to the Assistant Secretary at the US Department of the Treasury, where he advised Senior Treasury officials on tax reform options and issues. The first pillar is CEO commitment, top leadership buy-in to inclusion. Copyright 2014 - The 7 Pillars of Inclusion - All Rights Reserved The 7 Pillars of Inclusion framework was developed by Play by the Rules to help sports organisations assess where they stand with respect to the inclusion of disadvantaged… The US GILTI regime is different in some key respects from the proposed GloBE rules. During the current pandemic it's important that we all Play by the Rules - Australia's leading sports stars have a simple message, stick together, let's be a team and Play by the Rules. The second cap only applies where the Undertaxed Payment Rule is applied to entities resident in the same jurisdiction as the Ultimate Parent Entity. The aim of Undertaxed Payment Rule is to take the as yet unaddressed under taxation of income in a low-tax jurisdiction and allocate the taxing rights over that income to other jurisdictions by: The Undertaxed Payment Rule acts in a supporting role to the Income Inclusion Rule, examples of when the Undertaxed Payment Rule would be triggered include where: Which jurisdictions should be allocated taxing rights where there is interaction between the Income Inclusion Rule and the Undertaxed Payment Rule due to split ownership of a constituent entity can be complex. Similarly, under the second step, the maximum top-up tax allocable would be an entity’s net intragroup deduction multiplied by its local tax rate. For example, an entity resident in a jurisdiction that applies a CIT rate of 20% and is caught under the first step making a direct payment of 100 to a low tax entity can only have a maximum of 20 top-up tax imposed upon them under the first cap. We have outlined how taxing rights over income in a low tax jurisdiction are assigned to other jurisdictions. The 7 Pillars of Inclusion are the key elements that make inclusion happen. Playing next. Joshua D. Odintz is a partner in and on the management committee of Baker McKenzie’s North American Tax Practice Group. The Pillar One and Two Blueprints are now public documents ready to be analysed and assessed by businesses. Pillar Two seeks to adopt a broad definition for what are considered as Covered Taxes with a view to avoiding any legalistic or technical analysis when computing ETRs. Log In. Where the rule applies, the payer jurisdiction would impose a ‘top-up’ withholding tax. Here are a number of tools and resources to help you do just that. An ongoing area of discussion within the Blueprint is the impact of the carve out on Covered Taxes; whether Covered Taxes borne on Covered Income against which the carve-out is deducted should also be taken out of the GloBE tax base. An example is provided of a tax system that applies a 20% CIT rate but exempts 80% of all royalty receipts. In a year when COVID-19 has disrupted community sport and dried up club revenue streams from registrations. The Income Inclusion Rule adopts a top down approach whereby the jurisdiction in which the Ultimate Parent Entity is resident has the primary right to exercise taxing rights over income in a low tax jurisdiction. It is worth noting the United States does not enter into multilateral tax conventions (other than information exchange). The proposals would fundamentally re-shape international tax compliance. if a wholly owned subsidiary has an ETR of 7%, assuming a minimum rate of 10%, top-up tax at 3% should be applied at the level of the parent on the subsidiary’s undertaxed income). He is ranked as a leading tax lawyer by top legal directories, including Chambers Asia Pacific, PLC Which lawyer? As such, the threat of double taxation looms if Pillar One is not implemented in unison. Sections of this page. Regardless of status or fame, people are people. I am very honoured to be part of this Prince Mahidol Award Conference, in this panel on “interventions to reach the vulnerable.”. The Inclusion Framework uses the ‘7 Pillars of Inclusion’ model developed by Play by the Rules/Australian Sports Commission as the overarching inclusion philosophy. The Blueprint suggests that micro, small and medium sized enterprises should be out of scope, noting the EU’s definition as a possible basis, but seems inclined not to scope out groups larger than this but below the EUR 750m threshold. Covered Taxes are those that are applied to an entity’s income or profits, but with special rules to reflect the diversity of taxes applied across the world, particularly where taxes are applied in lieu of a corporate income tax (such as Saudi Arabian Zakat). To read our summary of the Blueprint for Pillar Two please click here. PBTR is a national initiative backed by Federal and State governments that promotes safe, fair and inclusive sport and provides an inclusive sport framework … Check them out... Join a fast growing community of people committed to safe, fair and inclusive sport. As such, whilst the Globe rules take up the bulk of the Pillar Two Blueprint, the Subject to Tax Rule operates in priority to the GloBE rules. Pillar Two is the second prong of the OECD’s Inclusive Framework plan to realign the international tax framework to adequately address the challenges of an increasingly digitalised economy and the first thing you should know is that it has nothing to do with digitalisation. The Inclusion Framework uses the ‘7 Pillars of Inclusion’ model developed by Play by the Rules/Australian Sports Commission as the overarching inclusion philosophy. The 7 Pillars of Inclusion are the key ingredients that make inclusion happen and are the common elements of inclusive practice targeting diverse population groups including people from different races and cultures, and people with disabilities. Recognising the compliance costs of the computational heavy GloBE rules, the regime is intended to apply to MNE Groups with global revenue’s exceeding EUR 750m threshold, in line with current Country by Country Reporting requirements. After much anticipation, the OECD released the ‘Blueprint‘ for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. The premise behind the Pillar Two proposal is simple, if a state does not exercise their taxing rights to an adequate extent, a new network of rules will re-allocate those taxing rights to another state who will. What percentages of payroll costs and tangible asset depreciation are taken into account in determining the carve-out is again a decision reserved for the politicians. the entity in the chain of ownership immediately prior to the point at which interests diverge. Since July 2019, Antonio is Chair of the Global Tax Practice Group. The 7 Pillars of Inclusion were born. The proposals open up as many questions as they answer. The IAP is based on the 7 Pillar of Inclusion model, which was developed by Play by the Rules (PBTR). Opinion Inclusive Education. The Subject to Tax Rule would apply where the recipient of a payment is subject to tax at an amount less than the nominal trigger rate. Your behaviour influences others, not only your team mates, but everyone involved in sport. Joshua is a frequent speaker at IFA, TEI, ABA Tax Section, NY State Bar Tax Section, Practicing Law Institute and Federal Bar Association tax meetings and conferences. Marnin Michaels is a partner in Baker & McKenzie´s Zurich office. A critical element of the GloBE base, particularly given the current economic environment, will be the extent to which losses are taken into consideration. Password: Forgot account? Joshua held high-level government positions with both the US Department of the Treasury and the Senate Finance Committee. Understandably the Inclusive Framework see that as a decision for the politicians to make, not the technocrats. 18:10. The illustrative examples provided by the Blueprint have assumed minimum rates that range between 10% – 12%. However, like the BEPS Action reports that came before them, the documents represent an evolution of the international tax framework that will influence tax policy for years to come. They cover a range of topics to help keep sport safe, fair and inclusive. Under the top down approach applied by the Income Inclusion Rule, where no entity in the chain of ownership is resident in a territory that has implemented the Income Inclusion Rule, taxing rights could be handed to the Head Office jurisdiction of an entity to apply them to the income of a branch established in a low tax jurisdiction. When it comes to creating an inclusive working environment, Garth talks about the four pillars of inclusion within an organisation. The US BEAT is broader than the Subject to Tax Rule in many respects. Press alt + / to open this menu. The rationale behind this is that the profits generated from tangible assets and personnel in a jurisdiction are less likely to pose a base erosion risk. However, the Income Inclusion Rule and the Undertaxed Payment Rule could be implemented just through changes to domestic law. Antonio lectures at numerous seminars and conferences around the world, as well as contributes articles to several international tax reviews. 'Conduct and behaviour' underpins organisational culture. Simply click on the links below or 'View All' to see the course requirements. Here, you can access resources to help you manage risks in your sport. Mutual agreement procedures could then apply to any disputes arising. The IAP is based on the 7 Pillars of Inclusion model, which was developed by Play by the Rules (PBTR). This can be called upon when the jurisdiction’s ETR falls below the minimum rate, ensuring local tax volatility does not trigger a top-up tax liability in the low years. A striking feature of the Blueprint is the sheer volume of computational complexity it imposes on MNE Groups. 8:23. In partnership with Play By The Rules and using the 7 Pillars of Inclusion model, these fun activities will help you to plan your inclusion activities. The Subject to Tax Rule only applies to particular covered payments made between connected persons. The Blueprint also discusses the relatively complex interaction between the Subject to Tax Rule and existing credits or exemptions under bilateral treaties. 7 Pillars of Inclusion The 7 Pillars of Inclusion is a national framework to assist organisations develop inclusion and diversity policies and strategies. Finally, the Inclusive Framework will also explore the development of a multilateral convention which could contain provisions for dispute prevention and resolution concerning the application of the GloBE rules as well as provisions for exchange of information between tax administrations. For US headquartered groups this could potentially mean that the GloBE rules do not affect them at all, or more likely they would be allowed to remove income within the scope of GILTI from its GloBE base leaving them to compute GloBE on subsidiaries outside the scope of GILTI or subpart F. A more difficult question is how the regimes interact where the US is an intermediate parent. Though requiring 248 pages of detailed technical analysis and examples in its ‘Blueprint’ document, once digested, the proposal is reasonably straightforward to understand at a high level (though the devil will of course be in the detail). Access - How to get there and get in After much anticipation, the OECD released the 'Blueprint' for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. Parents all want their children to shine on the sports field. The Blueprint also suggests that additional rules may need to be developed in order to ensure the “integrity and neutrality” of the Income Inclusion Rules is maintained. We have 23 million people, gathered from over 200 countries with 50% of us born overseas or with parents that were born overseas. Accessibility Help. In doing so, Pillar Two emphasises the need to consider the form and intention of the tax, irrespective of the name and mechanics of how a tax is applied. Earlier drafts of the Blueprint tentatively suggested a 3 year lookback period on entry into the regime. Inclusion and diversity in action. Jump to. There is information to help you understand the issue and tools to help you take action to address it. These could be implemented through bilateral negotiations and amendments to individual treaties or more efficiently through a multilateral instrument. Browse more videos. The Social Inclusion Framework uses the 7 Pillars of Inclusion model developed by Play by the Rules/Australian Sports Commission. The Baker McKenzie Global Tax Team has undertaken an in-depth analysis of the ‘Blueprint’ for the Pillar Two proposal to produce a digestible summary of everything you need to know. Unlike the Income Inclusion Rule or the Undertaxed Payment Rule, the Subject to Tax rule is not concerned with ETR; instead it looks to the nominal tax rate that applies to certain payments between connected persons. There is a significant overlap between the four components and it’s far from clear how they will interact. Facebook. Where the Income Inclusion Rule is unable to be applied to all of the income arising in a low tax jurisdiction, the Undertaxed Payment Rule kicks in. The global minimum tax regime imposed by the GloBE rules is principally imposed by the Income Inclusion Rule. In this section we explore how several sports have integrated the 7 Pillars of Inclusion model into their inclusion strategies, provide a range of useful interactive scenarios on successful inclusion, case studies on what others have done in this area, and resources and tools to assist you to make a difference. However, all other sectors are in the scope of Pillar Two. Beth Offenbacker, PhDD, Founder & Principal, Waterford Inc, July 11th, 2019. Recently I attended a meeting of the Inclusive Education Community of Practice, a group hosted by the Global Campaign for Education - US (GCE-US). If the Ultimate Parent entity is resident in a jurisdiction that has not implemented the Income Inclusion Rule, the taxing rights are passed down the chain of ownership until they reach an entity resident in a jurisdiction that has implemented it. Taking inspiration from GILTI’s deduction for qualifying business asset investment (QBAI), the GloBE tax base includes a formulaic substance based carve out calculated as a percentage of payroll costs and  a percentage of tangible asset depreciation. The critical component of this computation – what is the minimum acceptable ETR – has yet to be decided. Their contents reflect an extraordinary amount of work undertaken by the Inclusive Framework, made all the more remarkable by the difficult circumstances 2020 has brought upon us. This Rule broadly operates in a similar fashion to existing CFC regimes, however, unlike a lot of those CFC regimes it is solely concerned with low tax outcomes, not how taxpayers achieve those low tax outcomes. and Legal 500 Asia Pacific. Because the IIR tax credit is effectively a refund of minimum tax prematurely paid in a year where a jurisdiction appeared to be a low tax jurisdiction, the IIR tax credit can be offset against top-up tax liabilities arising in any jurisdiction. Once a jurisdiction has been identified as undertaxed, the difference between its ETR and the minimum rate, expressed as a percentage, is applied to the appropriately identified parent entity’s share of the undertaxed income (e.g. Although the 7 Pillars outlined in the video apply to all disadvantaged populations we’ll run through here how they apply only for people with disability. As such, Pillar Two does not impact the taxation of third party income received in the Ultimate Parent Entity’s jurisdiction. However, states keen to reach agreement on Pillar One may play hardball on Pillar Two to ensure the two come together as a package. This had been the subject of some debate amongst the Inclusive Framework, the alternative being to calculate on a global blended basis thereby allowing taxes paid in jurisdictions with tax charges in excess of the minimum rate to shield low taxed income. The OECD has now added substantial technical detail to the proposal and set out how the rules interact with one another. In recognition of this, the Blueprint suggests the following possible simplification measures to reduce the compliance burden: Another area where the Blueprint acknowledges further work is required is the interaction between the GloBE rules and the US GILTI regime. Salim has also represented companies in various alternative dispute resolution forums, particularly the Advance Pricing & Mutual Agreement Program.Salim is a frequent speaker on transfer pricing matters in seminars sponsored by various organizations and universities. The first cap ensures that the top-up tax imposed on an entity is not greater than the local tax effect of the payments which led to the top-up tax being allocated. Recognising that the Undertaxed Payments Rule is less accommodating, with no IIR tax credit to provide protection against timing differences, the second cap limits the top-up tax that can be applied under the Undertaxed Payment Rule to the Ultimate Parent Entity’s jurisdiction to the net amount of intra-group income it receives in the period tax effected at its local tax rate. The 7 Pillars of Inclusion presents a helicopter view of inclusion as a framework for greater levels of participation. Top 5 Pillars for Diversity and Inclusion Leadership Posted by: Nika White on Monday, January 16, 2017 Recognizing that diversity and inclusion is more than a moral challenge, but a business imperative requires linking D&I to the organization’s mission and explicitly assessing and identifying the value of diversity for the organization’s bottom line. The seven pillars are: Access; Attitude; Choice; Partnerships; … Mr. Michaels was a member of the firms Steering Committee leading the US Department of Justice Initiative for Swiss Banks. 1. payments for the use of software where the provider also provides ancillary support); Rent or any other payment for the use of right to use moveable property; Payments for services such as marketing, procurement, agency or other intermediary services where their value primarily derives from the use of an intangible asset (e.g. Whether a payment is subject to tax at less than the nominal rate would have regard to the tax rate directly applied (and, for this purpose, the taxes taken into account are proposed to be ‘covered taxes’ for the purposes of the OECD Model Tax Convention which may therefore exclude certain revenue-based taxes like digital services taxes), but also other contextual features of the recipient’s local tax system such as preferential rates or special exemptions, exclusions or reductions. Our training courses are online and/or face-to-face. The exception to this rule are split-ownership scenarios where a certain percentage (the paper suggests 10%) or more of the equity interests (being interests that give rights to profits) in a constituent entity are held by persons outside the relevant MNE group. The 7 Pillars of Inclusion. If there is still top-up tax to be applied after the first step, the second step is applied. The income inclusion rule creates several questions, including the level on which it would be applied (parent company jurisdiction, bottom-up, or other), an… The IAP is based on the 7 Pillars of Inclusion model, which was developed by Play by the Rules (PBTR). She is a member of the United Nations Sub-Committee on Transfer Pricing and continues to be involved in policy dialogue with OECD and non-OECD countries.She is a visiting Professor in several European Universities.She was the Head of the OECD Transfer Pricing Unit from 2001 to 2011. At the same time you also have responsibilities and you can play a huge role in creating a safe environment for your child. Yet there’s nothing that will dull a child’s sparkle more than having parents and spectators pressure them from the sidelines. When tax is paid in a jurisdiction in excess of the minimum rate, the excess is carried forward as a “local tax carry forward”. Prior to joining the Firm, Mr. Kelly worked as a partner in the Tax and Business Advisory Services Group at the Beijing office of one of China’s biggest accounting firms. Play by the Rules acknowledges the Australian Aboriginal and Torres Strait Islander peoples, Taking images of children at sporting events, Tips for the conduct of the Annual General Meeting. To the extent those paying group entities are resident in jurisdictions that have implemented the Undertaxed Payment Rule and are not also low tax jurisdictions, the taxing rights over the income arising in the low tax jurisdiction is allocated on a pro-rata basis. a royalty plus a payment for service), the rule would only apply to the constituent parts that are within scope. Create New Account. Yet at the same time, it attracts developmentalists His professional affiliations include serving on the editorial board of China Tax Intelligence—one of the premier China tax publications—and on the board of governors for the American Chamber of Commerce in Beijing. As such, the GloBE regime would operate in a similar fashion as the Alternative Minimum Tax that applied to US corporations prior to US tax reform in 2017. The 7 Pillars of Inclusion are the key ingredients that make inclusion happen and are the common elements of inclusive practice targeting The 7 Pillars of Inclusion is a broad framework to give sports clubs and associations a starting point to address inclusion and diversity. Here the Blueprint considers that the rate applied to royalties is 4%. Covered payments are those that are perceived to carry heightened base erosion and profit shifting risk: Where a payment is comprised of multiple elements (e.g. Join a fast growing community of people committed to safe, fair and inclusive sport. However, it is not clear whether these exclusions would align with those applied for the purposes of the GloBE rules, the Blueprint suggesting that this will be updated as ‘discussions develop’ with the ‘option to align the treatment’ with the GloBE exclusions. It has been adopted by a number of sporting organisations - from national to local level - including Swimming Australia and Netball Australia. Now is a good time to Let Kids be Kids. Sections of this page. Sign Up. The Subject to Tax Rule needing just 19 pages to explain could have just as great an impact on MNE Groups’ operating structures. Where the Ultimate Parent Entity is resident in a low tax jurisdiction, the Undertaxed Payments Rule would always apply in the first instance as no other entity sits higher in the chain of ownership, and therefore there is no other jurisdiction to which taxing rights can be allocated under the Income Inclusion Rule. Therefore, in theory, Pillar Two is capable of being implemented without agreement on Pillar One. In brief. Today sporting organisations at all levels need to be able to respond to complaints from their members and personnel about on field and off-field behaviour, such as inappropriate behaviour in the club rooms, at practice or on away trips. Partners: Play by the Rules In mid 2013 I was contacted by the then Manager of Play by the Rules and asked to look at developing a national framework for the greater inclusion of disadvantaged populations into sport. Blended ’ with higher-taxed income in the low tax outcomes are achieved is, on the management Committee of McKenzie! Make Inclusion happen should be aware of your clubs responsibilities area where Rule. And diverse being Undertaxed the proposed GloBE rules a helicopter view of Inclusion presents helicopter! Subject to tax Rule play by the rule 7 pillars of inclusion many respects to royalties is 4 % numerous seminars and around. At which interests diverge regime is different in some key respects from the proposed rules. Keep sport safe, fair and inclusive sport, complaint handling, for member protection information Officers and various.. Join a fast growing community of people committed to safe, fair and.. 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