Establishing a Business in the UK Guide

An Expert's View about Taxes and Accounting in the United Kingdom

Posted on: 4 Jun 2010

A comprehensive guide that provides, tax, structural and accounting advice to overseas business that are planning on establishing a presence in the UK.

Blick Rothenberg Establishing a Business in the UK 12 York Gate Regent?s Park London NW1 4QS United Kingdom T: +44 (0)20 7486 0111 F: +44 (0)20 7935 6852 E: W: Contents (Click to go to page) 03 Introduction 04 What creates a tax presence in the UK? 06 Registering an establishment or subsidiary 09 Accounting and related filing requirements 10 Corporation tax 12 Losses 13 The UK as a holding company location 14 Personal taxation 16 Share options 20 Social security 22 Value Added Tax (VAT) 24 Our team 25 Blick Rothenberg This booklet is for guidance only and advice should be sought to consider specific circumstances. page 02 Back to contents Introduction The United Kingdom (UK) has always been a major trading nation and partner for many other countries around the world. The country?s economy has evolved from being predominantly manufacturing based, to one that now is at the forefront of new developments in technology and biosciences. The development and expansion of the European Union (EU) has increased the UK?s attractiveness due to its excellent communication links to the rest of Europe. Where a company is looking to do We will therefore address what creates business with the UK, the fiscal a taxable presence in the UK, the implications are neither complicated procedures involved in setting up a nor overly burdensome. This booklet company here, tax rates, implications concentrates on providing practical for individuals working for a company, information that will inform and make and other related issues. it easier for overseas businesses to establish a presence in the UK. page 03 Back to contents What creates a tax presence in the UK? UK legislation provides that a UK corporate entity will be subject to UK tax. Furthermore, an overseas entity trading in the UK is likely to be subject to UK tax as well, but principally only on its activities in the UK. The issue to be considered is whether an activity creates a UK tax liability and, if so, what type of entity the overseas company should establish. any work permit issues) or having Alternatively, the overseas company The right entity ? trading with, someone based here on a more may decide at the outset that there or in the UK permanent basis. The role of this is an existing or potential market for Wher individual will be to research the it and would proceed to establish e a company is trading with market, maybe make initial contact a presence in the UK, which would the UK (i.e. has customers in the with potential customers, send have a corporate tax presence. In country to whom goods or services out marketing literature and other such circumstances the overseas are sold), there is unlikely to be a need similar promotional activities. In tax company needs to consider whether to establish an entity and comply with various r terms, these are generally known to register as a taxable establishment elated regulations (there as preparatory or auxiliary activities (formerly referred to as a ?branch?) or is one exception in relation to Value and commonly do not give rise a subsidiary. Added Tax which is considered on to any corporate tax implications. page 22). There is a need to register as an Establishment or subsidiary Wher establishment which is considered e a company is trading in the in the next section on page 06. We consider the procedures for UK, there are a number of factors to Local tax advice should be sought to registering an establishment or be considered. determine whether the activities of the subsidiary on page 06. This section establishment fall outside the scope considers the issues overseas In many instances, an overseas of UK corporate tax. The activities companies need to consider in business will initially wish to research outlined before may result in the choosing the correct entity. the market to see if it makes conclusion that there is a market commercial sense to establish a for the company?s goods/services An establishment is not a separate presence in the UK. This may either in the UK and even the wider legal entity from the parent company involve making frequent visits to the European market. but merely an extension operating UK (this booklet does not consider page 04 Back to contents Back to contents under the laws of another jurisdiction. As such, it does not provide the limited liability that a subsidiary company does. If the nature of the business is such that it is important to ring-fence liabilities arising in a specific jurisdiction, the subsidiary will afford the safer option. The other issue to consider is whether it is important for the overseas company to be seen to have a UK presence. Although an establishment and a company provide a UK presence, the perception is that a UK company is a local business with a greater sense of permanence. If this is important from a commercial perspective, you may wish to establish a subsidiary. The costs of maintaining an establishment or subsidiary need to be taken into account and these have a correlation to the level of filing requirements, which are considered in the following sections. Finally, is the group sensitive to the type and level of information that is publicly available about its business in its own jurisdiction? If it is, the subsidiary will be the better option. This is also considered in greater detail in the following section. Back to contents Registering an establishment or subsidiary It is normal for a company to have at Establishment least two directors to allow for greater efficiency in managing the company, The process of registering an should one director be absent. establishment involves the overseas company filing a form giving details There is no requirement for an officer of its shareholders and directors. It to be resident in the UK. also needs to submit with the form a certified copy of its memorandum There is no requirement for the and articles of association (company company to have a minimum amount bylaws or equivalent). If these of issued share capital. are not in English, they need to be translated. The form needs to Such a company is normally formed provide details of the UK address with one £1 issued ordinary share. from which business is going to be Paid up capital can be increased at conducted. The process of registering the time that the company is formed an establishment can take up to or later, depending on commercial three weeks but can be less if the requirements. documents mentioned above are readily available. The name chosen for the company must not be the same as, or similar Subsidiary to, an existing company?s name. It therefore makes sense to register a A subsidiary is also very easy to company as soon as a decision is establish. There are no statutory made to establish a UK presence. consents that need to be obtained prior to setting up the company. A company can be formed by submitting a form providing the consent of at least one person who is prepared to act as a director. As of 6 April 2008, there is no longer a requirement to formally appoint a company secretary, although there is still the requirement for the functions of a company secretary to be undertaken. This function is normally outsourced. page 06 Back to contents Back to contents ? makes sense to register a company as soon as a decision is made to establish a UK presence.? Back to contents Back to contents Back to contents Accounting and related filing requirements Subsidiary Establishment A subsidiary needs to prepare and If the law under which the parent file annually, a copy of its accounts is registered requires publication of prepared in accordance with UK audited accounts, a copy of those company law. The accounts, accounts needs to be filed in the UK. once filed, are available for public If the parent company has no such inspection. requirement, it must prepare and deliver for filing its accounts, prepared The accounts need to be filed within in accordance with the requirements nine months of its financial year-end. of UK company law. A company can choose its year-end, with almost all choosing one that The accounts that are filed are coincides with that of the parent available for public inspection in the company. UK. This can sometimes be an issue if the parent is not used to having its An audit of the UK company?s financial financial information made public. statements is required, if the group as In such circumstances, the parent a whole has: should either form a subsidiary rather than register an establishment or, in a. revenues exceeding £6.5million its home jurisdiction, establish another per annum; company which then registers the UK establishment. When the accounts of or the parent company are then filed, it only contains information relating to b. gross assets exceeding the establishment activities. £3.26million If the UK company does require an audit, the cost of maintaining the company compared to an establishment will be slightly higher. Remember though, that a company does provide the protection of limited liability. page 09 Back to contents Corporation tax Having registered an establishment or subsidiary we need to consider what level of corporate tax liability may arise in the entity. For this, one needs to determine both the applicable rate of tax and the level of taxable profits. If the UK entity is structured so that companies to pay taxation on account Tax rates it can enter into contracts with third before the year-end. party customers in its own right, The current rates of corporation tax it is more likely to have a buy/sell A company is defined as ?large? for are noted in table 01. arrangement. payment on account if either: In this case, sales to third parties a. its taxable profits exceed £10million Taxable profits will be recorded within the UK entity (or as appropriately divided by the accounts. number of associated companies in The level of taxable profits will, to the worldwide group); an extent, depend upon the trading model adopted (the comments that Intra-group and third party purchases and other costs of sales will be offset or follow apply to both an establishment against this, as will all overheads and a company). The UK has transfer and other intra-group and third party b. it was a large company in the pricing legislation which dictates that costs. twelve months preceding the period trading between connected parties and is also large in the current period. needs to be on an arm?s-length basis. In almost all circumstances, it is going For these purposes, ?large? is defined This is to stop international groups manipulating intra-gr to be necessary for the UK entity to as having taxable profits of £1.5million oup transactions undertake a transfer pricing study to or above (or as appropriately so that profits always flow to the prove that the pricing between the divided by the number of associated country with the lowest tax rate. parent and its UK presence is what companies in the worldwide group). would be agreed by parties acting on If the business model were such an arm?s-length basis. The corporation tax return needs to that the UK entity is to provide just marketing and technical support, a be submitted within twelve months of Corporation tax payment the year-end. A computation of the fee would be charged to the parent and return tax liability will also be submitted with for the services provided. It is this fee, the return. less related costs of providing these The corporation tax liability needs services and maintaining the entity, to be paid within nine months of the that would be subject to UK tax. company?s accounting year-end. There are provisions for certain ?large? page 10 Back to contents Back to contents Table 01 Corporation tax rates year to 31 March 2011 2010 Taxable Profit % % £ (Note 1) Small company rate 21 21 0?300,000 Intermediate rate 29.75 29.75 300,001?1,500,000 Full rate 28 28 Over 1,500,000 Notes: 1. The profit limits are reduced where there is more than one company under common control in the worldwide group. If there is a parent and a subsidiary under common control the limits are all divided by 2. 2. The rate of tax applicable to an establishment will be considered by reference to the combined profit of the establishment and the overseas parent. This is only for purposes of determining the appropriate tax rate and only the establishment profits are taxable in the UK. Back to contents Losses The d ecision on whether to register an establishment or a subsidiary could be affected by the anticipated results of the business in its formative stages. If an establishment incurs a loss, If a subsidiary is formed and it incurs These losses, however, are generally this could be available for offset losses, these can be carried forward not available for offset against the against parent company profits, in the indefinitely for offset against future parent company profits. parent?s jurisdiction. Additionally, the taxable profits of the subsidiary, establishment losses can be carried providing they are from the same forward in the UK for offset against trade. future taxable profits. page 12 Back to contents Back to contents The UK as a holding company location The UK is an attractive location for establishing a holding company, one that conducts business in the UK, but which is also utilised to expand into other parts of the world. If the UK company was utilised to From 1 July 2009, virtually all All of the above has made the UK a hold shares in other companies, and dividends received by the UK parent, very attractive location for forming a such shares were subsequently sold, whether in the UK or from overseas, holding company. the resulting gain is exempt from are exempt from UK tax. tax providing the company held at least 10% of the shares and it was The UK itself does not levy a a trading company, or was part of a withholding tax on dividends paid trading group before and after the to its shareholders, whether UK transaction. or overseas based. Furthermore, because of the network of double The UK company can also act as tax treaties, the parent company will the holding company which either not suffer double taxation in its own forms establishments/branches or jurisdiction when it receives dividends subsidiaries in other parts of the from its UK subsidiary. world. The wide network of double tax treaties that the UK has entered into means that withholding taxes on dividend payments from overseas jurisdictions to the UK parent will be minimised. page 13 Back to contents Personal taxation circumstances, be determined Basic principles Taxation of employment by reference to whether he/ income of non-UK domiciliaries she is regarded as habitually or As a general principle, if an individual ordinarily resident here (i.e. their is resident in the UK in any tax year, If a person is resident and ordinarily ordinary residence status). An he/she will be subject to UK tax resident in the UK, he/she is liable individual?s ordinary residence laws. However, the basis on which to UK tax on the total income from status would depend upon their the individual is subject to UK tax an employment if the duties of that will depend on not only whether the intentions in coming to the UK, the employment are performed at least accommodation they occupy and the person is ?resident? here but also partly in the UK. This applies whether whether they ar length of their stay.e ?ordinarily resident? or not the income is remitted to or here. In certain circumstances one paid in the UK. An individual would normally become also needs to consider the person?s ordinarily resident from the day of ?domicile?. However, if the employee has a their arrival where they intend to stay separate employment with a non-UK in the UK for three years or more, The UK tax year runs from 6 April to resident employer, the duties of which or where they either own or lease the following 5 April. A reference to a are performed wholly outside the UK, accommodation in the UK for three 2010/2011 fiscal period refers to the the individual will be liable to UK tax years or more in the year of arrival. personal tax year 6 April 2010 to 5 only if the income is remitted or paid Otherwise, an individual will become April 2011. to the person in the UK. ordinarily resident from the beginning of the tax year during which such If the employee is resident but not accommodation is acquired, or during Residence ordinarily resident in the UK, he/she which they decide to stay in the UK will be liable to UK tax on the part of for three years or more, or following A person is resident in the UK if the employment income relating to the third anniversary of their arrival in he/she: duties performed in the UK, wherever the UK. paid. If the employee works outside ? visits the UK regularly and on the UK, employment income for that average for more than 90 days a work is generally taxed only on the Domicile year over a four year period; amount remitted to or paid in the UK. A person?s country of domicile is ? arrives in the UK intending to stay If a non-domiciliary who has been broadly the country that they consider for at least three years; resident in the UK for seven out of the to be their permanent home. The last nine tax years wants to retain the concept of domicile is quite distinct ? is in the UK for more than 183 days benefit of this status, he/she must pay from that of residence. A country of in a tax year. a £30,000 annual charge. domicile is sometimes referred to as the person?s ?homeland?. Even if you Or have not lived in your homeland for dinary residence many years, this does not prevent a person from being domiciled there. In addition to residence status for a particular tax year, an individual?s chargeability to UK tax may, in some page 14 Back to contents Back to contents Table 02 Taxable income Personal tax rates Taxable income includes all income & allowances and benefits. The rates of personal taxation are shown to the right in table 02, together with the level of personal allowances. These are % Band of Taxable amounts that each individual is able Income (£) to earn before becoming liable to taxation. Year to 5 April 2011 Tax free allowance £6,475 * Detached duty relief 20 1?37,400 40 37,401?150,000 Where an overseas national is 50 Over 150,000 seconded to the UK to work for the UK entity for a period which Year to 5 April 2010 is less than two years, he/she Tax free allowance £6,475 can take advantage of detached 20 1?37,400 duty relief. This allows the individual?s employer to provide 40 Over 37,400 accommodation, travel and other similar benefits tax free. These * Income of more than £100,000 sees the personal allowance reduced by 1/2 of income would normally be taxable items over limit. on individuals not qualifying for detached duty relief. page 15 Back to contents Share options Share incentive schemes can often be an attractive part of an individual?s total remuneration package. The UK has certain ?approved? schemes which provide considerable tax advantages to the employee. There are, however, pitfalls as well as reporting obligations. This is an area of considerable complexity which cannot be addressed within this booklet. The following section, on pages 17?18, summarises the types of schemes available. However, detailed advice should be sought as soon as consideration is being given to establishing a scheme or granting options under an existing scheme. page 16 Back to contents Back to contents Share option schemes Her Majesty?s Revenue & Customs Enterprise Management Savings Related Share Option (HMRC) ? No approval, but necessary Incentive Scheme (EMI) Plan (SAYE options) to notify HMRC of option grants under Outline this scheme (certain requirements to ? Up to £120,000 of options Outline ? In conjunction with monthly be met). per employee (but restricted if CSOP savings contract, savings of £5 to options also held - see below). £250 per month can be accumulated Options must be capable of being to purchase shares on exercise of Company Share Option Plan exercised within ten years of grant. options (after three years). Options Options can be granted at a discount (CSOP) should be granted at prevailing share from prevailing share values if values. (Maximum annual value = Outline ? Up to £30,000 of options required. £3,000). granted to employees, exercisable between three to ten years from grant. Income Tax ? If granted at a discount, Income Tax ? Can avoid PAYE & NIC. £30,000 = total value of options as this will be subject to Income Tax No Income Tax charge on grant or when options ar at date(s) of grant. Options should be e exercised (?Pay when the employee exercises the granted at prevailing share values. As You Earn? (PAYE) & ?National options. Insurance Contributions? (NIC) Income Tax ? Can avoid PAYE & NIC. can apply to this element) and if Capital Gains Tax ? CGT will be No Income Tax charge on full amount restrictions apply, there may be further payable at 18%, or for 5% holdings when the employee exercises the Income Tax charges when shares by directors or employees in trading option. are sold, or restrictions lift, otherwise companies, may be taxed at 10% on no Income Tax or National Insurance gains up to £1million. Capital Gains Tax ? CGT will be Contributions on grant or exercise. payable at 18%, or for 5% holdings Who can ? Must be available to all by directors or employees in trading Capital Gains Tax (CGT) ? CGT on employees on similar terms. companies may be taxed at 10% on gain when shares sold, deduction gains up to £1million. for any value charged to Income Tax. HMRC ? Requires HMRC approval. CGT will be payable at 18%, or for 5% (Various requirements to be met). Who can ? Not available for holdings by directors or employees in employees holding 25% or more of trading companies may be taxed at share capital. Company has some 10% on gains up to £1million. discretion over which employees Who participate.can ? Any number of employees, providing total value of EMI options HMRC ? Requires HMRC approval. granted is no greater than £3million. (Various requirements to be met). Company must be mainly trading in UK (or a qualifying subsidiary trading in the UK). Company (or group) must have gross assets less than £30million. Shares must be issued by parent company. page 17 Back to contents Share option schemes (cont.) Unappr Who can ? Company has full oved Share Option discretion over which employees may Scheme participate. Outline ? No limit on value of options HMRC ? No approval required. granted to employees. Options can be exercisable at any time. Options can be granted at a discount from Share Incentive Plan (SIP) prevailing share values if required. Outline ? Shares held in trust for Income Tax ? Can be subject employees. Company can offer up to PAYE & NIC. No Income Tax to £3,000 shares (?free shares?). charge on grant Income Tax charge when exer Scheme can allow employees to cised and if restrictions purchase further £1,500 shares apply there may be further Income (?partnership shares?) - using income Tax charges when shares sold or before tax & NIC. Company can restrictions lifted. match these with further free shares (?matching shares?) - up to two for Capital Gains Tax ? CGT will be each share employee acquires. payable at 18%, or for 5% holdings (Maximum shares = £7,500 per by directors or employees in trading annum). companies, may be taxed at 10% on gains up to £1million. Income Tax ? Can avoid PAYE & NIC. Who can No Income Tax charge on acquisition ? Company has full of shares. Income Tax charge if discretion over which employees may shares are withdrawn from trust participate. before five years. Capital Gains Tax ? No CGT on value Phantom Share Scheme of shares on withdrawal from trust Outline after five years. CGT on gain when ? Bonus paid to employees shares sold (if previously held in trust based on increase in value of shares. for full five years: base cost = value (No shares actually provided to on exit from trust). Taxed at 18% (a employees). 5% shareholding is highly unlikely). Income Tax ? PAYE & NIC will apply. Who can ? Must be available to all Income Tax charge on full amount when paid to employee. employees on similar terms. HMRC ? Requires HMRC approval. Capital Gains Tax ? No CGT (as no (Various requirements to be met). shares received). Can be expensive to set up and run. page 18 Back to contents Back to contents Back to contents Social security Table 03 Social security, otherwise known as National Insurance rates National Insurance (NI) in the UK, is payable by both the employer and year to 5 April 2011 employee. The current rates of National Insurance contributions by the employer and employee are shown to the right in table 03. The UK has concluded Reciprocal Rate Agreements with a number of countries under which, if the overseas national seconded to the UK continues to pay the equivalent Employer Up to £5,720 0% of National Insurance in his home Over £5,720 12.8% country, the employer and employee will be exempt from paying National Insurance. The countries with which the UK has such agreements and Employee Up to £5,720 0% the number of years for which £5,720?£43,888 11% exemption may be granted, is shown to the right on page 21. Over £43,888 on excess 1% page 20 Back to contents Back to contents Exemptions must be formally obtained Reciprocal agreements in each instance. Countries with which the UK has The exemptions, when first sought, a convention whereby overseas can usually be obtained for a fixed nationals working in the UK do not period which is unlikely to exceed have to pay National Insurance (NI) five years. Exemptions beyond five are as follows: years will only be considered in very rare circumstances. It is important to ? All members of the European note that the agreements for different Economic Area (this includes countries work in different ways and Austria, Belgium, Bulgaria, further advice should be sought with Cyprus, Czech Republic, regards to specific countries. Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, The Netherlands, Norway, Poland, Portugal, Republic of Ireland, Romania, Slovakia, Slovenia, Spain, Sweden & Switzerland). ? Barbados ? Bermuda ? Bosnia-Herzegovina ? Canada ? Croatia ? Israel ? Jamaica ? Japan ? Jersey/Guernsey ? Macedonia ? Mauritius ? Montenegro ? New Zealand ? Philippines ? Republic of Korea ? Serbia ? Turkey ? USA page 21 Back to contents Value Added Tax (VAT) VAT is a sales tax. It is chargeable by businesses if they are making supplies (sales) above a certain threshold. The current threshold for registering for VAT is £70,000 per annum. If the threshold is exceeded or and businesses which are not c. Goods supplied to the UK ? an expected to be exceeded in the near registered for VAT or make exempt overseas company, not having a future, the business must notify the supplies. permanent establishment in the UK, authorities and register itself to be does not have to register for and able to charge VAT on the supply of There are a number of important charge VAT. This is as long as the UK goods and services. The current rate issues that overseas businesses customer is importing the goods into at which VAT is charged is 17.5%. looking to establish a business in the the UK. If the customer is expecting UK need to be aware of: to take delivery of the goods only When a business is registered for VAT after they reach its premises, the it must charge VAT at the appropriate a. Goods and services supplied to overseas company may have to rate on the value of all sales of goods a parent company based outside register for VAT in order to first and services made in the UK, unless the European Union (EU) ? if the UK recover the VAT paid at the border on they are specifically zero-rated or entity established by the parent sells importation of the goods. Once it has exempt. goods to the parent there is no VAT done this, it will then have to charge chargeable as this is an export. If the VAT on its invoices, even if raised by Where a business is registered subsidiary provides services such as the overseas company as the goods for VAT, the charge to it of VAT on consultancy, technical support and will now be deemed to have been purchase of goods or services is marketing these are not subject to physically supplied in the UK. not a cost. This is because it is VAT. able to recover this VAT from the The need for the overseas company Government. At the end of every b. Services supplied to the UK ? to register for VAT described above calendar quarter, the business an overseas company, not having does not necessarily require it calculates the amount of VAT it has its own permanent establishment to register an entity. This would charged to its customers as well as in the UK (its taxable establishment be dependent upon the issues that which it has paid to its suppliers. or subsidiary in the UK, for these discussed earlier in this guide and The net amount, depending on purposes, is treated as a separate not just because certain supplies of whether more has been collected or entity) does not have to register for goods are made in the UK. paid, is either paid to the authorities or charge VAT as long as it is making or claimed back from them. VAT is those supplies from outside the UK. ultimately only a cost to individuals page 22 Back to contents Back to contents d. Supply of goods and services within the European Union ? a UK entity, registered for VAT, does not have to charge VAT on the supply of most goods or services to businesses in other EU countries as long as they too are registered for VAT in their own country. An overseas company established outside the EU will sometimes suffer UK or European VAT before it has established a business in the UK or the wider European market. This could be in relation to costs of business trips (hotels, etc.) or maybe exhibitions attended as participants. This VAT can only be reclaimed under a special provision whereby a claim can be submitted to the authorities for this VAT to be repaid. Where a business registers for VAT it can reclaim VAT on goods and services purchased prior to registration - provided the goods are still on hand at the time of registration and for services, these were supplied no more than six months prior to registration. Back to contents Our team Nilesh Shah Steven Bruck Bob Rothenberg MBE US/Canada/India Germany/Austria/Switzerland Asia/Pacific +44 (0)20 7544 8866 +44 (0)20 7544 8970 +44 (0)20 7544 8888 nilesh.shah steven.bruck bob.rothenberg @blickr Colin Lehmann Melissa Thomas Simon Wagman France/Italy Canada/US Israel +44 (0)20 7544 8833 +44 (0)20 7544 8938 +44 (0)20 7544 8828 colin.lehmann melissa.thomas simon.wagman page 24 Back to contents Back to contents Blick Rothenberg Blick Rothenberg is a leading UK accounting and tax practice specialising in helping overseas companies establish a presence in the UK. Based in Central London, the practice has 22 partners and 160 staff with exceptional experience and expertise in all the major financial disciplines. We aim to make the process of establishing and maintaining a UK presence by an overseas entity as easy as possible. We can assist with the correct tax structure and entity formation, as well as all year-end requirements such as audit, accounts and tax filing. We also have considerable expertise in advising overseas nationals seconded to work in the UK ( We currently act for over 500 administer invoicing, debt collection, Fluency Solutions Limited can overseas companies and have expense payment, management provide a centralised solution to the also recognised the need to assist accounts, European VAT reclaim, etc. challenges of international expansion them manage their UK presence. ( ( To this end, our wholly owned subsidiary, BRAL Limited, provides If, on the other hand, you are an a full outsourced accounting and overseas business with operations administration service. BRAL can in a number of different territories, Blick Rothenberg is authorised & regulated by the Financial Services Authority to carry on investment business. 2010/11 edition Last updated 04/10
Posted: 04 June 2010

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