In today’s article, we will explain for whom it is more advantageous to obtain Cypriot non-dom status and how to utilise it. We will also explain in which cases residency in Cyprus is not a good idea.
For years, the most popular tax residence in the European Union has undoubtably been that of the Mediterranean state of Cyprus. The Anglo-Greek south of the island has benefited significantly from its non-dom programme, which guarantees foreigners exemption from tax on dividends and interest income for the first 17 years.
However, since the start of the non-dom status over 6 years ago, the conditions in Cyprus have significantly changed and worsened.
In any case, residency in Cyprus for many people continues being a great, if not unbeatable, option. However, for others residency is too expensive and inflexible a measure, often the result of misleading self-promotion by local agencies or law firms.
When you finish reading this article, I hope that you will have a more detailed picture of the current situation in Cyprus. Here is our previous article in which we explained in depth how the non-dom works in Cyprus. That article is more basic and summarised as well as a bit outdated in certain points, however you might want to start there and then read this one.
Next, we would like to review the status quo in Cyprus by looking at a few examples, and reveal for whom this option will still be interesting in 2022.
It’s essential to have an in depth understanding of tax residency, which gives certain groups of people undeniable advantages, but may not be of interest for others.
In particular, the groups of people who benefit most from tax residency in Cyprus are:
- People intending to live in an EU country for more than 183 days per year.
- Businessmen who will maintain companies in their country of origin, especially if it’s in Europe.
- Online Businessmen selling physical products in the EU.
- Businessmen with intellectual property involved in the US market.
- Investors in start-ups and venture capital in Western countries with high taxation.
- Investors with investment strategies that lead to receiving interest and dividends.
- Investors in EU real estate.
- People who need a tax certificate for any reason.
- People that a country can make into a tax resident.
- People wishing to postpone their exit tax in Spain.
If you don’t fall into any of the above categories, you should ask yourself if it’s really in your best interest to move to Cyprus, especially if you have no interest in living there in the first place.
Instead of wasting 60 days a year on this island, you could enjoy other regions that are more appealing to you. Or, if there is another country you prefer, you can arrange to spend more time there.
Do I need a tax residence in Cyprus?
Local advisors and lawyers like to sell a misleading image of Cyprus, claiming that tax residency is mandatory and that pure perpetual travelling isn’t legally feasible. Fortunately, this is categorically untrue.
Tax residency is not a prerequisite so that the majority of migrants live tax free. The fact that you can obtain tax residency in Cyprus after only 60 days is undoubtably a great advantage. However, the country offers more leeway than many would have you believe. From a purely practical point of view, the Cyprus tax residence certificate would only be relevant for you in the following cases:
Continuous proof of tax residence in EU territory (necessary if for example you are deferring Spanish exit tax)
Many businessmen emigrated to Cyprus at the end of 2021, mainly because a stay of only 60 days instead of the usual 183 allowed them to defer exit tax.
If you are subject to exit tax but don’t want to pay it, you have the option of becoming a resident in a country within the European Union. This way, you could defer the exit tax until you escape it (10 years). For this to work without any problems, you must be able to prove that you live and are tax resident in a country within the EU. If you cannot provide such proof, the exit tax may be activated automatically.
To avoid withholding taxes due to double taxation treaties signed by Cyprus
For many, this is the most important point that leads them to seek tax residence in a particular country. Double tax treaties between two countries can only be officially used by those who have a permanent establishment or tax residence in one of the signatory states. The tax residence certificate will be required from any person applying for the benefits provided in the agreement.
In the US, this happens through the W8 forms, which exempt from withholding tax. Cyprus has an excellent double tax treaty with the US which reduces dividend and interest income to 15%. Withholding taxes on many royalties are even reduced to zero. However, in almost all other countries, you would have to actively seek reimbursement. In general, it’s only worthwhile to go through this application process when large sums are involved. In any case, the tax certificate is a relevant document for this.
The advantages of Cyprus’ treaty can not only be used at a personal level, but also at a corporate level and companies benefit from it by the mere fact of having a permanent establishment. Those who don’t wish to spend 60 days in Cyprus can benefit from the same advantages by setting up a Cypriot company which has the necessary business structure (an office and employee who is paid at least €450 per month). Interest and dividend income as well as capital gains are exempt from taxation in Cypriot limited partnerships, even without non-dom status. Moreover, the absence of withholding taxes allows dividends to be transferred tax-free to other tax havens.
However, this is only worthwhile for large sums given that maintaining a Cypriot company without being a Cypriot resident would cost between €10,000 and €12,000 per year (due to the necessary business foundation). Given the 15% tax (withholding) savings on US shares, it would only really be profitable for you from a large dividend of €100,000 per year.
Cypriot tax residency can also be of interest if you are an investor, follow dividend or interest strategies and are looking for a base in Europe.
If, on the other hand, your income solely or mainly comes from capital gains (profits on the sale of shares), you will not need a Cypriot tax residency. Even as a perpetual tourist without any residency, capital gains would be free of tax and withholding tax. However, you will need to have an address to adhere to the broker’s KYC (Know Your Customer) identification and verification procedures.
The shielding affect of double taxation agreements
On a personal level, the shielding affect of double taxation agreements is often more relevant than the possibility of avoiding withholding tax in the first place. Having a treaty you can rely on is crucial, especially if you still have economic interests or a home in your country of origin.
Cypriot tax residency protects you particularly if you still have regular onsite work to do in a country which has signed an agreement with Cyprus. Therefore, you could be a Cypriot tax resident and pay tax in Cyprus as a non-dom, as long as you spend at least 60 days on the island and less than 183 days in the other country that you are visiting.
In any case, we recommend that you study the matter in depth if you are going to remain closely connected to your country of origin, so that the Tie-Breaker Rules are clearly set in favour of Cyprus. (For example in a consultation with denationalize.me).
Bear in mind that if there is no clear winner after applying the tie-breaker laws, the citizens would ultimately decide, which can be fatal in many cases.
As a bridge country for certain cases
Some countries will require (or prefer) that you provide them with a tax residency certificate in your new country of residence, before you can deregister as a tax resident.
In such case where you cannot immediately become a perpetual tourist, spending a year in Cyprus could be beneficial.
Moreover, leaving Cyprus as a non-dom does NOT require a new tax residence. In principle, the return of the yellow slip with the termination of residence and departure from the country is sufficient to terminate the tax liability in Cyprus.
However, make sure you report your departure from Cyprus, as remaining a resident in Cyprus as a non-dom without meeting the minimum residency requirements can be dangerous.
If you continue to live in Cyprus, and keep your registration certificate etc, they can integrate you into the normal Cypriot system with a 17% tax on dividends and interest income. The best thing to do here is to cut your losses.
There are no laws in Cyprus which make it difficult to leave, except for the exit tax. However, this is only applicable after 7 years of Cypriot tax residency. Moreover, it’s very easy to avoid structurally given that the sale of company shares is tax-free. So, don’t let a possible exit from Cyprus keep you awake at night!
Very short-term emigration (less than 2 years) with the intention of returning to your country of origin
If you wish to return to your country of origin after a short time, the situation may change. In this case, to avoid them trying to make you a tax resident during your stay abroad, it would be useful to have a tax residence certificate in another country for the year that you were away.
This won’t necessarily happen, but it is a potential risk, especially if you return home after only one or two years.
It’s not a question on whether you’ve paid taxes during that time, but of having actually lived abroad and being able to prove it (in this case with a tax certificate).
Should you choose to live as a Perpetual Tourist or as a resident in Cyprus?
Nearly every week, we receive clients who want to give up their Cypriot residency and become perpetual tourists, given its greater flexibility.
As already discussed in the previous paragraphs, a large number of people can do this without any many problems. Many people don’t need the Cypriot tax residency certificate. If we look at it more closely, Cyprus has many disadvantages for “stateless” people, despite its enormous advantages compared to typical Western tax hells. We will discuss these disadvantages in detail below.
Flexibility as a perpetual tourist
Tax residency in Cyprus requires a minimum stay of 60 days as a classic non-dom or 183 days if you opt for the non-dom residency route as a High Net Worth Individual (HNWI). Cyprus is not part of the Schengen zone, so it has border controls which are difficult to bypass. We aren’t going to get into certain possibilities of entering the island via the northern border which could allow you to enter and leave the country without any record of it.
Cyprus is by no means a bad place to live. Many businessmen who initially only planned to spend 60 days a year on the island, have ended up staying much longer because they enjoy it. Others, on the other hand, don’t grow accustomed to the county or other options arise. At the end of the day, 60 days is only a sixth of the year.
Unlike being a resident in Cyprus (or any other country where you want to become a tax resident), as a Perpetual Tourist you do not have a minimum stay anywhere. Yes you do have a maximum stay, but this is also the case in Cyprus. If you spend more than 184 days or more in another country, you would no longer be considered a non-dom in Cyprus.
If you are a perpetual tourist, given that you are not personally protected by the double taxation agreements, you will also have to be more careful with other aspects of the centre of vital interests compared to what would happen if you had a non-dom status in Cyprus.
About legal security
For EU citizens, which Cyprus is a part of, has certain advantages like its ease for immigration. However, this partnership with the EU also comes with significant disadvantages, due to the increasing pressure to align with the rest of the member states. This could make residency in Cyprus less and less attractive. Those who have been living in Cyprus for some time have already seen how many things have changed for the worse.
The good news is that dividends and interests are guaranteed to be tax-free for the first 17 years after you’ve become a non-dom in Cyprus. This has also been formally approved by the EU and, in our opinion, will remain unchanged for existing non-dom residents.
However, it is only a matter of time before Cyrpus stops accepting new non-dom applicants. Initially, this special status was only meant to be available until 2021. For now, there’s no end date in place, but the time will come when one will be set and then the door will be closed for new residency applicants.
The bad news is that Cyprus cannot tax dividends but it can add other taxes. For example, receiving dividends now also requires you to pay compulsory state health insurance. In state redistribution systems, percentages and the tax ceiling are likely to increase.
An increase in corporate tax from 12.5% to 15% has already been approved under the pressure of the EU. The increase isn’t drastic but it shows where the EU’s harmonisation efforts are going. Once a uniform minimum of 15% tax on all EU member states is put in place, we cannot rule out increases. At the end of the day, there would no longer be tax competition. The EU’s original plans foresaw a minimum corporate tax of 28%. Fortunately, despite corporate tax increases, there is still the possibility to work through tax-free foreign companies. We will tell you exactly how this works later on.
However, the situation has become a lot more difficult in this area as well. In the early days of the Cypriot non-dom status, it was easy to set up a shell company anywhere in the world. However, now at least one trustee is needed as well as the corresponding additional costs and it’s also not possible to divert up to 70% of the Cypriot company’s profits like before. Due to harmonised transfer pricing legislation, this can only be done on a small scale.
Other advantages that existed in Cyprus, such as the IP Box (or Patent Box), which allowed an effective taxation of 2.5% on all copyrights, can no longer be used in 2022.
Finally, the sword of Damocles which is the grey lists of organisations such as the Financial Action Task Force (FATF) always looms over Cyprus. The FATF’s money laundering list is a popular tool for pressuring tax havens to reform, as the country’s inclusion on the list causes major problems in opening bank accounts for all Cyprus residents and companies.
Nowadays, there are many good banking solutions that aren’t available to Cypriot residents or companies.
Therefore, we can see that finding long-term legal security, residency in Cyprus (or any other European country) has some disadvantages. On the other hand, however, if we have if we have too strong ties with certain countries, it may still be safer to acquire residency in Cyprus than to be a Perpetual Tourist. This way you will be more protected against other counties’ attempts to make us tax residents.
As a perpetual tourist, it is normal to have very low costs. Often all you need is residency on paper to comply with the banks requirements. This is something that we can get through friends or family (by paying other people’s consumer bills).
If you don’t have this option, you can rent a house with your several friends in the same situation. In any case, it isn’t necessary to rent or buy a house, although, depending on the case, buying a house could be interesting as an investment and a way of receiving passive income (with its rent).
Since you have complete freedom in choosing where to set up your business, you can basically work without tax or accounting. The classic solution of setting up a US LLC in a complete package costs €1200 per year with us (first year €1800).
As for house insurance, you can take out international health insurance to cover you anywhere in the world through us.
For most perpetual tourists, just the structural costs of the company, health insurance and bank compliance should not surpass €200 or €300 per month.
On the other hand, settling in Cyprus as a non-dom comes with considerably higher costs. The requirement to rent or buy a home raises the costs significantly. Yes, it’s possible to rent homes without legal residency in order to meet the requirement (on paper) of having a house available all year round, but even in these cases you won’t be avoid paying at least €200 a month. Furthermore, if you want a normal house, which you can live in, it will be difficult to find something for less than €600 a month.
Moreover, it’s also true that you can often convert two thirds of your flat into an office and having a flat would naturally save you accommodation costs in comparison to life as a perpetual tourist. Of course, this implies that you have to live in Cyprus all the time. Like HNWI, Cyprus is less flexible – 183 days minimum stay – but beyond rent, you’ll only have to pay for compulsory state health insurance. At 2.6% of all income and capped at around €250, you can’t say it’s a bad deal.
Elderly people with preexisting illnesses will prefer to opt for Cyrpus, instead of having to find and pay for private health insurance.
Young and healthy businessmen, however, pay significantly more as residents in Cyprus than if they opted to be a perpetual tourist, especially above a certain income level.
Of course, if you want to travel and be covered, despite having health insurance in Cyprus, you will need to take out another one that has coverage outside of the EU.
As a HNWI, you will also have to take into account the structural costs of potential foreign companies that you will need if you aren’t purely living off your investments. These are definitively higher than those for perpetual tourists, since at least one trustee is needed to legally hold foreign companies from Cyprus (we’ll explain this in detail later).
Classic non-doms should set up and keep a Cypriot company and pay themselves at least the minimum wage as their salary. This salary is tax-free up to €19,500 but it requires a contribution payment of 8.3% by the employer (deductible) and the worker.
If we assume typical use of full tax relief, it will lead to social security costs of €3,000 per year, part of which is deductible. If you only pay yourself the minimum wage, this sum would be around €2,000.
Of course, it’s important to take into account that this expense protects you against risks such as accidents, the need for care and even unemployment. In comparison to other European social security systems, the benefits in Cyprus are abundant in relation to the costs. However, this can be dealt with more economically in the private sphere, without relying on a state social security system.
Social security costs must be added to the Cypriot structural society costs. Depending on the law firm, you will most likely have to pay between €2000 and €6000 for full administration and tax support. In addition, bank fees are usually relatively high in the inconvenient and substandard Cypriot banks. Since most businessmen can use their home as a place of work, they’re saving money from office expenses. However, don’t forget the 12.5% corporation tax, although you can deduct a lot, this is where the biggest proportionate costs emerge as your income increases.
Both options of residency in Cyprus, whether it be the classic partnership or as a HNWI with foreign companies and trustees, it will cost a minimum of between €6,000 and €10,000. Moreover, you have to take into account the necessary accommodation and the various consumption costs in the country.
In total, if you’re opting for Cypriot residence, minimum costs of €12,000 a year (€1,000 a month) should be taken into account. On the other hand, the majority of perpetual tourists can live with significantly lower costs.
For the businessmen with low income, Cyprus’ fixed costs are usually too high and higher-income businessmen lose large sums in corporate tax. Fortunately, it is legally possible to reduce this to zero and we will show you how to do this in the next section. However, even here there are still comparatively high costs, a loss of flexibility and increasing legal uncertainty.
Living completely tax-free with your tax residency in Cyprus
We are now going to see a practical example, Ana’s case, who emigrated to Cyprus in 2018, attracted by the idea of living on this beautiful Mediterranean island. Ana applied for non-dom status by registering a Cypriot limited company, from which a tax-free salary is paid regularly but subject to social security. As a non-resident, she is guaranteed 17 years of tax-free dividend and interest income. However, she isn’t immune to the changes in other aspects: Cyprus’ compulsory 2.6% health insurance took her by surprise, as well as the increase in corporation tax to 15%.
Ana wants to stay in Cyprus, but she doesn’t want to subject herself and her business to the legal uncertainty of an EU country where constant measures are expected to be put in place to catch up with other European countries. She could have just as easily stayed in her home country.
Ana is an online coach with an income of €240,000. About half of her clients are businesses and they need deductible invoices, but what hurts Ana the most is the VAT on the other half of her individual clients. Since her place of work is Cyprus, she has to add it onto the invoices.
Ana would not mind enjoying a lower corporation tax and have better banking options and facilities than those offered by Cyprus. This is why Ana is looking for alternatives in her Cypriot company.
One day she found our denationalize.me tax-free and no accounting offer LLC and she asked us about it. Unfortunately, we had to give her some bad news because with Cypriot residency, the LLC won’t work.
Solution for Ana’s case
Cyprus’ special tax regime as a non-dom country exempts dividends from taxation, but not earned income or profits received from a partnership such as an LLC. Those other types of income are subject to progressive taxation of up to 35%, plus social security, which is around 15%.
Therefore, it is normal to pay yourself a salary from the Cypriot LLC in a tax free amount of €19,500 and distribute the rest as tax free dividends. The problem is that LLCs are fiscally transparent and cannot distribute dividends.
The LLC’s profits are directly transferred to its member and should be taxed in their country of tax residence, and not in the USA. This is ideal for territorial, tax-free income residency or as a perpetual traveller. However, for those in the Cypriot non-dom regime it is a major tax trap. Fortunately you can resolve this problem by using a company in a tax-free country as the owner of the LLC. This way, the LLC channels the income to a tax-free offshore company, which in turn can distribute it appropriately in the form of dividends. This is something we have already done with multiple clients who wanted to enjoy the advantages of an LLC as residents in Cyprus. The good thing is that the LLC’s status as a disregarded entity in the USA doesn’t change, it remains tax free. Currently, the combination of an LLC with an offshore company in the Seychelles or in the Emirates is the most popular. However, Panama can also be a good option.
At this stage you might be wondering, and rightly so, why not just work directly with an offshore company and bypass the LLC.
In certain cases the Emirates company could be fine, for example if you directly sell to private individuals (B2C) and can deal with the limited banking and collection options. However, for those who need to be able to process payment via credit cards, better banking and a higher reputation, it is better to create an additional LLC on top of this company. Clients would undoubtedly prefer to receive invoices from a US LLC rather than from a company in Panama or the Seychelles.
As well as saving on the potentially increasing corporation tax, in theory there is also an enormous VAT advantage. If you can credibly prove a place of supply of services outside Cyprus (because, for example, you live elsewhere for 10 months of the year or have employees outside the country), you will not have to pay Cypriot VAT. For standard B2C services, no VAT is due if the place of performance is outside the EU. VAT only applies to automated digital products and physical goods.
Even if the place of performance is actually in Cyprus, there will be a practical advantage in the VAT payment in most cases. The important thing is to credibly present a foreign company.
In order for Cyprus to approve this approach, certain conditions must be met. In recent years, Cyprus has become increasingly stricter, but it still doesn’t have an external tax legislation as strict as other countries. The Cyprus CFC-Rules for example exclusively apply to companies, not individuals. Therefore, it is important that the structure described is not created from a Cypriot holding company. (Although, on the other hand, you have to take into account what will be put in place from mid-2023 with the new corporate tax rate of 9% in the Emirates).
In any case, these CFC rules don’t apply to individuals such as shareholders. Only the classical effective direction rule applies here. The foreign company must not be managed from Cyprus so that it does not give rise to a local permanent establishment. However, contrary to what happens in other countries, the Cypriot tax administration still accepts the use of trustees. It doesn’t necessarily have to be a general manager with power of attorney and a reasonable salary: a fiduciary service, such as the ones that lawyers often offer, would be sufficient nowadays. (Although, having said that, a more credible manager never hurts).
In practice, this director must appear in the company register and sign certain documents. Cyprus makes sure that the shareholders’ resolution on the distribution of dividends is not signed and executed by a director that is also a shareholder. In principle, with Cypriot residency, you can set up and manage companies anywhere in the world according to the model we’ve just explained.
Some countries are better than Cyrpus in terms of taxation even within the EU, especially if certain turnover thresholds are not met. Some examples would be 5% general IS in Malta, 5% in Lithuania on the first €300,000 of profits or 1% in Romania on the first €500,000 of turnover. If you go outside of the EU, there are many other options than the Seychelles, Panama or Emirates
However, we recommend said jurisdictions because our associates can offer very profitable fiduciary services tailored specifically to Cyprus’ legal system. For a Seychelles company with a trustee director, you will need to budget around €5,000 per year. For a company with a trustee director in the Emirates, we would be talking around €10,000 a year. If you need an additional LLC, you will only have to pay €1,800 more.
The trustee of the offshore company can and should also register as the manager of the LLC. The director should be someone whose nationality and residence doesn’t hinder the opening of accounts and who can submit the provide the necessary KYC (Know Your Customer) documents without any problems.
Naturally, with the current corporate tax rate of 12.5%, you could say that you pay relatively little in Cyprus. However, the costs of a tax-free offshore structure are only within a profitable range for annual profits in the 5-digit range and they often offer better banking options than those available in Cyprus.
Businessmen who opt for the rarely considered option of applying for the non-dom status for high net worth individuals (HNWI) have considerable cost advantages. This is because they save the costs of the Cypriot limited company and social security which cost to no less than €5,000 a year. Contrary to the classic non-dom scheme with a Cypriot limited company, this option requires a minimum stay of 183 days in Cyprus. In order to be considered as a high net worth individual and qualify for the HNWI programme, it may be useful to deposit a ridiculous €30,000 in a bank account. Many Cypriot businessmen are surprised by the HNWI option. The majority of tax advisors will not tell you about it because they would stop making money from the sale and maintenance of Cypriot companies. However, this is undoubtedly a better option for those who want to spend most of the year in Cyprus.
This way, you can directly manage tax-free foreign companies in exchange for paying only a few thousand euros more than with a Cypriot company.
You can also choose the structure we have already discussed or the classic non-dom with a Cypriot limited company. In doing so, you would only pay extra for a company that you would (hardly) use, but you would gain the freedom of only having to spend 2 months in Cyprus per year. For serial entrepreneurs, of course you can also choose to have companies in Cyprus and abroad.
If, like Ana, you also reside in Cyprus and want to improve your situation, don’t hesitate in booking a denationalize.me consultation. Whether you want to continue living on the island or if you are tired of it, we can offer you personalised solutions so that you can make the most of your situation. The tax-free Cyprus solution with a suitable foreign company and a local manager is ideal for many branches of business. However, for certain companies, a Cypriot company or even a pure tax free domain is sufficient. Below, we would like to briefly highlight said cases again.
For whom is residency and/or business in Cyprus still worthwhile?
The tax-free Cyprus solution with a suitable foreign company and a local manager is ideal for many branches of business. However, for certain companies, a Cypriot company or even a pure tax free domain is sufficient. Below, we would like to briefly explain again the cases for which residency in Cyprus may be a good idea.
- People who don’t want to constantly be travelling and who want to live in an EU country for more than 183 days.
- Those subject to Spanish exit tax and want to avoid it or at least postpone it.
- Businessmen with companies in other EU countries who want to take advantage of the benefits of a strong double taxation treaty such as the one with Cyprus.
- Investors in start-ups and venture capital who want to enjoy a capital gains tax-free country.
- Investors who receive interest and dividends.
- Online businessmen who sell physical products in the EU.
- Businessmen with intellectual property who want to avoid copyright withholding taxes. You have 0 rate from the US market. (For example, this affects business models that rely on Amazon Kindle or Amazon Merch, or the development of software for the Google and Apple).
- Property investors in the EU. Cypriot limited companies can be used to invest in and manage real estate in other EU countries. This has no tax advantages per se, but it can guarantee a greater anonymity and help with future sales (Share Deal).
- People who need a tax certificate for any reason.
So, will Cyprus continue being a good option for me in 2023?
This article does not by any means intend to disparage Cyprus, it is a very attractive island with numerous advantages. However, we can’t ignore the fact that it also has some disadvantages, many of which the result of its membership of the European Union.
In this article we have solely analysed Cyrpus from a fiscal point of view, as any other approach would be too individual and subjective to generalise.
Some businessmen like Cyprus so much that they stay on the island for more than 6 months a year, whilst others find it difficult to meet the required 60 days. Both groups of people can benefit from the analysis we’ve presented you with today.
Those who wish to stay in Cyprus have the option to further optimise their taxes through a tax-free foreign company. However the limited Cypriot company, whether it be operational or as a holding company, is usually still the best option. And for anyone who is thinking of leaving Cyprus, we hope that after reading this article you will be able to further gauge whether it is the right choice for you. Denationalize.me can help you with any situation: whether you have decided that you want to be a HNWI in Cyprus, or you would prefer to spend only 60 days there as a classic non-dom, or you have even decided that the Perpetual Tourist route is the best for you. Please don’t hesitate to contact us if you have any questions about this, if you need advice or if you decide to leave accounting and taxation behind with a US LLC instead of a Cypriot limited company.
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