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Taxation, Tax-Planning & Double Tax Treaties

The Law Firm provides for Tax Planning advice to clients wishing to optimise their international business activities. Cyprus is the European country with the most favourable tax system and has a wide network of Double Tax Treaties. The legislation effective since January 2003 has abolished the distinction between local companies and International Business Companies (IBC) and created one form of Cyprus Company.

Cyprus tax residence
An individual is resident if he lives in Cyprus for one or more periods which exceed the total of 183 days per fiscal year. Residents are subject to tax in Cyprus on their worldwide income, whilst non-residents are subject to tax only on their income derived in Cyprus. A company is resident if its management and control is in Cyprus, which in practical terms means that the company must have a majority of Cyprus resident directors.

Corporation Tax
All Cypriot companies pay corporate tax except shipping companies which pay tonnage tax.

The corporate tax rate is 12.5% except for royalties.

Since, January 1st 2012, royalties are exempt from corporate tax for up to 80%, net of direct expenses, with the remaining 20% being subject to 12.5% corporate tax, thus giving an effective intellectual property tax rate of 2%.

The 80% exemption on profits arising from intellectual property assets applies after deduction of all direct expenses including amortisation on the cost of acquisition of IP assets and interest expenses to finance the acquisition and/or development of the IP assets.

80% of profit generated from the disposal of IP net of any direct expenses and owned by a Cyprus resident company is exempt from income tax.

IP assets include all intangible assets, copyrights, patents and trademarks.

Fixed annual levy of € 350

A fixed annual levy of € 350 applies to all companies including dormant (non active) companies and companies that do not own any assets or own property not controlled by the Republic of Cyprus.  

The first levy is imposed on the year of incorporation of the company.

The non-payment of the annual levy will result in de-registration or strike off the company from the Cyprus Registrar of Companies.

 

Where a company is re-instated in the Registrar within 2 years from de-registration or strike off date, an additional fixed penalty of € 500 will be imposed.

Where a company is re-instated in the Registrar after the 2 year period, the fixed annual levy will be increased up to € 750.

 

The late payment of the annual levy results in the following penalties:

-In case of delay up to 2 months, 10% penalty.

-In case of delay from 2 to 5 months, 30% penalty.

Dividend income
Dividend income received in Cyprus from a foreign corporation is wholly exempt from corporation tax in Cyprus and not subject to Special Defense Contribution Tax of 17% as long as the company receiving the dividend owns shares in the company paying the dividend, even if the shareholding is less than 1%. However, this does not apply if more than 50% of the paying company's activities result in investment income (passive income such as interest from companies,bank accounts,royalties which does not derive from trading, commercial, manufacturing or similar activities) and the foreign tax is significantly lower than the tax rate payable in Cyprus in other words less than 5%. Furthermore, dividends are not considered investment income if derived from trading subsidiaries. Under Cyprus law, dividends should be distributed every two years. If a Cyprus resident company does not distribute dividends within two years from the end of the tax year, 70% of accounting profits are deemed to have been distributed, 17% special contribution for defence is imposed on deemed dividend distribution applicable to residents shareholders, deemed distribution is reduce with payments of actual dividends which have already been paid during the two years from the profits of the relevant year, and when an actual dividend is paid after the deemed dividend  distribution, then special contribution for defence is imposed only on the additional dividend paid.

Interest income
Active Interest acquired from the usual activities of the company (such as interest on trading, current accounts, debtors, finance, banking, inter-company finance) is subject to income tax at 12.5%. Passive Interest not acquired from the usual activities of the company credited or received by Cyprus residents (such as interest paid on bank deposits) is subject to Special Defence Contribution Tax of 30%. Interest income from savings bonds and development bonds and all interest earned by a provident fund is subject to special contribution for defence at 3%. 

Special Defense Contribution Tax (SDC)
The application of Special contribution for defence to Dividend Income and Interest Income is described the above two paragraphs. Most companies are not affected by SDC but income tax.

Payments of dividends, interest and royalties to non-residents
There is no withholding tax on payment of dividends, interest to non-resident individuals or corporations, irrespective of the existence of a Double Tax Treaty or of the country of residence of the recipient. The same applies to royalties as long as the license has been granted for use outside Cyprus, otherwise there is a 12.5% tax.  

Profits from abroad
Profits earned from a permanent establishment abroad are fully exempt from corporation tax, except if more than 50% of the paying company's activities result in investment income and the foreign tax is significantly lower (by at least 5%) than the 12.5% tax rate payable in Cyprus. 

Gains from disposal of securities - full exemption from capital gains tax and income tax
There is no taxation on the profits from the disposal /sale of securities for all the companies and individuals that are tax residents of Cyprus irrespective of whether the gain is of capital or revenue. It allows the Cyprus Holding Company to dispose of the shares in a subsidiary with no tax in Cyprus, and allows the disposal of shares of a Cyprus Holding Company with no tax in Cyprus irrespective of the provisions of a relevant Double Tax Treaty.

According to the new Law 118(1)2002 which applies since January 1rst 2003, securities also known as Titles include shares, debentures, government bonds, founder's shares or other securities of companies or other legal entities incorporated in Cyprus or abroad and stock options thereon.It allows 0% tax on profits made from the sale of shares bought before or after 1/1/2003 from another company abroad, with the sale of the shares taking place after 1/1/2003, and without affecting the value of shares.Finally, a ruling in Cyprus is possible in order to determine whether an instrument qualifies under the law as Security or Title. 

Capital gains
Capital gains realized on immovable property held outside Cyprus are outside the scope of capital gains tax. A capital gain realized on immovable property held in Cyprus is 20%. The full capital gains tax exemption on profits from the disposal of securities does not apply to the disposal of shares of a Cyprus company owning immovable property, the sale of the property and the disposal of the shares being subject to 20% Capital Gains Tax.

Transfer Pricing - Arm's length
The arm's length rule does not apply on transactions between a Cyprus parent company and its directly 100% owned Cyprus resident subsidiary.

Tax losses

Trading losses may no longer be carried forward indefinitely; unutilized losses will be extinguished after five years.

 

EU Parent - Subsidiary Directive 
Its application in Cyprus abolishes withholding taxes upon the subsidiary for dividends paid to its mother Company resident in any member state, as long as the mother Company has its tax residence in a member state and possesses 10% or more of the shareholding of its subsidiary for any period of time (the original EU Directive implies 25% and a time period of a few years).

EU Interest and Royalty Directive

The “Interest and Royalty Directive”, which provides for exemption from withholding tax over interest- and royalty payments between certain affiliated EU-companies. Companies are considered to be affiliated in this sense if one of the companies at the minimum holds 25% of the share capital in the other company or if a third company at least holds 25% of the share capital in each of the two companies (or, upon discretion of the Member States, 25% of the voting rights). Considering its low (12.5%) corporate income tax rate (which is one of the lowest in the EU), the availability of this Directive and the availability of a significant number of double tax treaties, Cyprus is an interesting jurisdiction for setting up a (group) finance company or (group) licensing company within the EU and/or outside the EU. Additional advantage of licensing via Cyprus is the afore-mentioned possibility to obtain tax exemption for the gain upon the sale of the IP used for the licensing activities.There is no withholding tax in Cyprus over interest payments to non-resident creditors, nor is there (as mentioned) withholding tax due over royalty payments in case the license has been granted for use outside Cyprus. The EU-Directives and Cyprus’ double tax treaties in many cases provide for substantial reduction or even elimination of withholding tax over the interest and royalty payments to the Cyprus finance- or license-company. In Cyprus, there are broad possibilities for the credit of any foreign withholding tax still payable over the interest- and royalty payments against Cyprus tax due over the corresponding income.

Unilateral tax credit relief
In practice this means that a tax credit is given in Cyprus on any tax including Special Defence Contribution Tax and Income Tax for any tax paid in the foreign state jurisdiction including underlying local trade tax paid by the subsidiary company or withholding tax on outgoing dividends to Cyprus.

Group relief
Group relief provisions allow companies of the same group to transfer losses from the loss making companies to profitable companies as long as all companies of the group are Cyprus tax residents. In order for two companies to be considered part of the same group both must be subsidiaries of a third company for 75% of their shareholding or one company must be the subsidiary of the other for 75% of its shareholding, in the sense that the holding company holds directly or indirectly 75% or more shares, benefits directly or indirectly to 75% or more of the income and of the assets in case of winding up, of the subsidiary company.

Reorganisations, Mergers, Acquisitions, Amalgamations
The new Cyprus tax legislation has adopted in a more liberal version the appropriate EU Commission Merger Directive 2005/56/EC which enables reorganizations (merger, division, transfer of assets and exchange of shares) and amalgamation of companies without corporate tax, capital gains tax or transfer fees. Reorganisations apply to physical or moral entities of member and non-member states of the EU. 

Re-domiciliation
According to articles 354A to 354P of the Cyprus Companies Law Cap113, Cyprus Companies and foreign companies based in Cyprus can be re-domiciled abroad, thus giving the possibility for foreign holding companies to move to Cyprus without creating a problem to their overall tax structure.

Listing in Stock Exchanges
Cyprus companies including the Cyprus Holding Company can list at the Cyprus Stock Exchange or any other proper international stock exchange, as long as the Memorandum & Articles of the Cyprus company is changed into that of a Cyprus Public Company, the Cyprus Public Company lists its shares, and the services of a broker are used for the application for listing and the listing process, and the preparation of the admission documents.

Thin Capitalization Rules
Cyprus laws do not provide for Thin Capitalization Rules, thus Cyprus companies do not have to comply to any debt to equity ratio. This allows the possibility for a Cyprus company to acquire loans and to deduct interest paid to the mother company.

Controlled Foreign Company (CFC) Legislation  
Cyprus laws do not provide for CFC Legislation and according to the jurisprudence of the European Court of Justice has ruled that CFC rules can not apply when the subsidiary company in a Member State has true economic activities, thus it is to the advantage of businessmen to use the Cyprus company as a subsidiary company or The Cyprus Holding Company as a mother company to which income from zero % jurisdictions or passive activities cannot be related. 

Estate Duty 
Estate Duty was abolished in Cyprus on January 1st 2000. 

Stamp Duty 
Stamp Duty applies to contracts, documents, etc. which relate to assets in Cyprus irrespective of whether or not these were signed in Cyprus. Transactions related to reorganizations and contracts relating to assets or business outside Cyprus are exempted from stamp duty.

VAT
The Standard rate of  VAT in Cyprus as of January 2014 is 19%, with a reduced rate of 9% for matters related to restaurant services, tourism and transportation, a reduced rate of 5% on the construction or acquisition of residential property in Cyprus used as primary or permanent residence by locals or foreigners whether residents or non-residents of Cyprus, a reduced rate of 5% or 0% rate for various product supplies, and exemption on financial services, hospital and medical services, postal services, insurance services, rental of immovable property and disposal of immovable property where the application for building permission was submitted prior to 01/05/2004. Added value tax is imposed on the provision of goods and services in Cyprus as well as on the importation of goods into Cyprus. It is imposed on all supplies of goods or provision of services made within the Republic which are not exempt (taxable transactions). The place of supply for goods is where the goods are located when they are delivered to the client. Services are considered to be rendered in the place where the person who is rendering them belongs (basic rule) unless the services fall within certain categories for which special rules apply. For example, special rules apply for advertising, intellectual property rights, certain professional services, telecommunications which are considered to be rendered in the place where the recipient of the services is considered to belong. The person rendering the services is considered to belong in a given country if he has a business establishment there and not somewhere else or he does not have such an establishment anywhere but his habitual residential place is there (for legal persons this is the country of their registration) or he has such establishments in that country and somewhere else but his establishment more closely connected to the supply is located in the give country. Therefore based on the above, depending on the nature of their supplies and where they belong, Cyprus Companies could be liable to registration, could be entitled for registration or will neither have the right nor the obligation for registration.

- Liability for Registration: A Cyprus Company which makes taxable supplies within Cyprus is liable to register if the value of their supplies exceeds the registration threshold which is currently € 15,600. If taxable supplies are taxed with the standard rate of 17% or reduced rate of VAT they must account for output on these supplies. Liability to register may also arise due to the reverse charge provisions for services received from abroad. They must treat such supplies as if they had been supplied by them in Cyprus in the course of their business and account for VAT. Such VAT, if attributable to taxable supplies, will give rise to the right of deduction as input tax. However, if this is the only sole type of “supply’’ of a Cyprus Company in Cyprus which is not registered and their value exceeds € 15,600 p.a. then liability to register for VAT purposes is born. If a Cyprus Company makes supplies which are taxable under the zero rate of VAT it becomes liable to register if the value of these supplies exceeds € 15,600 p.a. despite the fact that no output tax will have you be accounted for. 

- Voluntary Registration: Cyprus Companies established in Cyprus making supplies which are considered to be provided outside of Cyprus have no liability to register for VAT. However where a Cyprus Company which is not liable to register under the VAT law and provided certain conditions are met (among others business establishment, registration, or management and control in Cyprus etc) it can voluntarily register for VAT if it so desires and be registered from the day on which the request is made or from such earlier date as may by agreed with the VAT office. The above provisions allow Cyprus Companies which have been established in Cyprus to register for VAT, even though, they will not have account for any output tax. As a result, they will be eligible to recover VAT charged on taxable supplies received and on importation of goods. It must be note that Cyprus Companies whose taxable turnover does not exceed the € 15,600 can also apply for voluntary registration.

- No liability and no right for registration: Cyprus Companies which have been established in Cyprus and supply, amongst others, the following services which are exempted from VAT are note liable or entitled for registration: The supply of financial services, insurance and reinsurance transactions including those performed by insurance agents, brokers, and broker’s agents; Interest receivable and rents receivable, regarding leasing or letting of immovable property.

Taxation of individuals    
An individual is considered to be a resident of the Republic of Cyprus when he is present in the Republic more than 183 days in a tax year. Where an individual is a resident in the Republic, tax is imposed on income accruing or arising from sources both within and outside the Republic. Where an individual is not a resident, tax is imposed on income accruing or arising only from sources within the Republic.
Chargeable income (after all allowances) is taxed as follows:

-up to EUR19,500: Nil

-from EUR 19,501-28,000: 20%, Cumulative tax: EUR 1700,00

-from EUR 28,001-36,300: 25%, Cumulative tax: EUR 3775,00

-from EUR 36,301-60,000: 30%, Cumulative tax: EUR 10885, 00

-above EUR 60,001: 35%

-As per January 1rst 2012, an employer taking up residence in Cyprus with a yearly salary above EUR 100, 000 benefits from a 50% tax exemption for a period of 5 years.

 

Double tax Treaties 
*
For Dividends, Interest & Royalties received (Rcvd) in Cyprus, the tables show the rates of withholding tax deducted in countries that have signed a double taxation treaty with Cyprus from income to be received in Cyprus. The withholding tax paid abroad is credited against any tax payable in Cyprus, if any. Furthermore, there is no tax in Cyprus for dividends received from another Cyprus company, for dividends received from another foreign company of which the Cyprus Company receiver holds 1% or more of the shares, or for dividends received from a foreign company with a Permanent Establishment in Cyprus.

** Payment of Dividends & Interest paid from Cyprus to non-residents is exempt from withholding tax in Cyprus. Interest paid from Cyprus bears a 15% withholding tax if it doesn’t fall within the usual activity of the Company. Royalties paid from Cyprus for use outside of Cyprus are free of withholding tax in Cyprus but bear a 10% withholding tax if they are for use within Cyprus.

***Armenia, Kyrgyzstan, Moldova, Tajikistan, Uzbekistan and Ukraine consider themselves bound by the treaty signed with the former USSR. The rates shown are those of the treaty Cyprus/USSR.

 

 

Country

 

Dividends %

 

Interest %

 

Royalties %

 


Received in Cyprus

 

Paid from Cyprus

       

Received in Cyprus  

               

Paid from Cyprus

 

Received in Cyprus

 

Paid from Cyprus   

Armenia

        0 (30)

 0 (30)

5

 5

5

 5

Austria

10

10

0

 0

0

0

Belarus

5 (17)

 5 (17)

5

5

5

 5

Belgium

10 (8)

 10 (8)

10(6, 18)

10(6,18)

0

 0

Bulgaria

5 (22)

 5 (22)

7 (6,23)

 7 (6)

10 (23)

 10

Canada

15

 15

15 (4)

15 (4)

10 (5)

10 (5)

China

 10  10  10  10  10 10

Czech Rep.

 0 (28)
0 (28)
 0 0
 0(29)  0(29)

Denmark

 0 (6,32)
 0 (6,32)  0 0
 0 0

Egypt

 15  15  15 15
 10  10

Estonia
 
0
 
0
 
0
 
0
 
0

0

Finland

5(35)
 
5(35)

0
 
0
 
0
 
0

France

10 (36)
 0
 10 (10)
 10 (10) 0 (3)
 0 (3)

Germany

5(36)
 5(36) 0
 0
0
 0

Greece

 25
 25 10
10
 0 (11)
0 (11)

Hungary

 5 (8)
 0  10 (6)
 10 (6)
0
 0

India

 10 (37)
 10 (37) 10 (10)
10 (10)
15 (14)
10 (15)

Ireland

 0 0
 0  0  0 (11)
0 (11)

Italy

 15 0
 10 10
 0 0

Kuwait

 0  0 0
0
5
5

Kyrgyzstan(19)

 0  0  0 0
 0 0

Lebanon

 5  5  5
 5
0
 0

Malta

0
 15 10
10  
 10 10

Mauritius

 0  0  0  0 0
 0

Moldova

 5 (26)
5 (26)
 5 5
 5  5

Montenegro(25)

10
 10  10 10
 10 10

Norway

 0(12)
 0  0  0  0 0

Poland

 0(34)  0(34) 5(6)
 5 (6)  5 5

Portugal
 
10
 
10
 
10
 
10
 
10
 
10

Qatar

 0  0  0  0  5(27)  5 (27)

Romania

 10  10 10 (6)
10 (6)
 5 (7)
 5(7)

Russia

5 (16)
5 (16) 
0
0
 0  0

San Marino

 0  0 0
0
 0 0

Serbia (25)

 10  10 10
10
 10 10

Seychelles

 0  0  0 0
 5 5

Singapore

 0 0
 10 (6,24)
 10 (6,24)  10 10

Slovakia

 10 10
10 (6)
10 (6)
5 (7)
5 (7)

Slovenia

5(31)
 5(31)  5  5 5
5

South Africa

 0  0  0 0
 0  0

Spain
 
0(39)
 
0(39)

0

0
 
0
 
0

Sweden

 5 (8)
 5 (8) 10 (6)
10 (6)
 0  0

Syria

 0 (8)
 0 (8) 10 (4)
 10 (4) 10
 10

Tadzhikistan(19)

0
 0  0 0 0
 0

Thailand

10
 10  15 (20)
 15 (20)  5 (21)
 5 (21)

Ukraine (33)

 5 (19)
 5(19)
2
 2 5 (33)
5 (33)

U.K.

 15(13)
 0  10 10
 0 (3)
 0 (3)

USA

 5(9)
 0  10 (10)
 10 (10)
 0 0


Notes:   
    1. Under Cyprus legislation there is never any WHT on dividends and interest paid to non-residents of Cyprus.
    2. Royalties earned on rights used within Cyprus are subject to WHT of 10%.
    3. A rate of 5% on film and TV royalties.
    4. Nil if paid to a government/Central Bank/Public Authority or for export guarantee.
    5. Nil on literary, dramatic, musical, or artistic work.
    6. Nil if paid to the government/Central Bank/Public Authority of the other state.
    7. This rate applies for patents, trademarks, designs or models, plans, secret formulas, or processes, or any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.
    8. A rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.
    9. A rate of 15% if received by a person controlling less than 10% of the voting power of the paying company and in all cases if received by an individual.
    10. Nil if paid to a government, bank or financial institution.
    11. A rate of 5% on film royalties.
    12. A rate of 5% if received by a person controlling less than 50% of the voting power.
    13. This rate applies to individual shareholders regardless of their percentage of shareholding. Companies controlling less than 10% of the voting shares are also entitled to this rate.  Companies controlling at least 10% of the voting shares are entitled to nil WHT.
    14. A rate of 10% for payments of a technical, managerial, or consulting nature.
    15. Treaty rate is 15%, therefore restricted to Cyprus legislation rate.
    16. A rate of 10% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 100.000.
    17. If investment is less than EUR200.000, dividends are subject to 15% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company.
    18. No WHT for interest on deposits with banking institutions.
    19. A rate of 15% if a dividend is paid by a company in which the beneficial owner holds less than 20% of the share capital of the paying company and the beneficial owner has invested less than Eur 100.000.
    20. A rate of 10% on interest received by a financial institution or when it relates to sale on credit of any industrial, commercial, or scientific equipment or of merchandise.
    21. This rate applies for any copyright of literary, dramatic, musical, artistic, or scientific work. A 10% rate applies for industrial, commercial, or scientific equipment. A 15% applies for patents, trademarks, designs or models, plans, secret formulas, or processes.
    22. This rate applies to companies holding directly at least 25% of the share capital of the company paying the dividend. In all other cases the WHT is 10%.
    23. This rate does not apply if the payment is made to a Cyprus international business entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity.
    24. A rate of 7% if paid to a bank or financial institution.
    25. Serbia and Montenegro apply the Yugoslavia/Cyprus treaty.
    26. This rate applies if received by a company (excluding partnership) that holds directly 25% of the shares. A rate of 10% applies in all other cases.
    27. Applies to any consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, tapes or discs for radio or television broadcasting), computer software, any patent, trademark, design or model plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience.
    28. This rate applies if received by a company (excluding partnership) which holds directly at least 10% of the shares for an uninterrupted period of no less than one year. 5% applies in all other cases.
    29. 10% for patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
    30. A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR150.000.
    31. The provisions of the Parent-Subsidiary EU directive are applicable.
    32. A rate of 15% if received by a company controlling less than 10% of the share capital of the paying company or the duration of any holding is less than one uninterrupted year.
    33. A 5% WHT will be levied on payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience.  10% WHT will be levied in all other cases.
    34. This rate applies if the recipient company (excluding partnership) holds directly 10% of the shares for an uninterrupted period of at least 2 years. 5% in all other case.
    35. A rate of 15% applies if received by a company controlling less than 10% of the voting power in the paying company and in all cases if received by an individual.
    36. A rate of 15% if received by a company holding less than 10% of the share capital of the paying company and in all cases if received by an individual.
    37. A rate of 15% if received by a company holding less than 10% of the shares of the paying company and in all cases if received by an individual.
    38. The treaty with Spain is expected to be effective during 2014 in relation to WHT.  The WHT provisions of the treaty will be effective after the period of 3 months from the date of exchange of notes between the two countries.
    39. A rate of 5% if received by a company holding less than 10% of the share capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares.

 

A tax-sparing provision has the effect that if tax is 'spared' ie exempted in Cyprus, then it is credited against an investor's tax liability in his home country (the treaty counterpart) as if it had actually been paid in Cyprus. There are tax-sparing provisions in the treaties with the following countries:



 

  • Canada
  • Czech Republic
  • Denmark
  • Germany
  • Greece
  • India
  • Ireland
  • Italy
  • Malta
  • Romania
  • Slovakia
  • Sweden
  • Syria
  • United Kingdom
  • Yugoslavia

The taxes all or partly spared are as follows:
  • Tax on interest paid on loans for economic development in Cyprus (Canada, Denmark, Germany, France, UK)
  • Tax relieved because of deductions in respect of investment in Cyprus (Canada, UK)
  • Tax on interest or profits which is unpaid because of tax incentives, reliefs or exemptions in Cyprus (Czech Republic, Greece, Ireland, Romania, Slovakia, Yugoslavia)

Tax not withheld on dividends (15%) if the exemption is given for the purposes of economic development in Cyprus (Denmark, Germany, France).

 

 

 

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