International Taxation: Capital Gains - Comprehensive Guide for CA Final Students

Capital Gains taxation in an international context is a highly complex and critical area for CA Final students, forming a significant part of Paper 4 (Direct Tax). It involves navigating the interplay of domestic tax laws (Income Tax Act, 1961), a taxpayer's residential status, the source rules for income, and the provisions of Double Taxation Avoidance Agreements (DTAAs). Understanding these nuances is crucial for advising on cross-border transactions and for scoring well in examinations.

Quick Answer for Featured Snippets:
Capital gains in international taxation are primarily governed by the residential status of the taxpayer, the situs (source) of the capital asset, and the specific provisions of the Income Tax Act, 1961, read with applicable Double Taxation Avoidance Agreements (DTAAs). Key complexities arise from indirect transfers, specific non-resident taxation regimes (e.g., FII/FPI), and treaty override principles.

Introduction to Capital Gains in International Taxation

The taxation of capital gains arising from cross-border transactions is a cornerstone of international tax. It involves determining which country has the right to tax the gain – the country of residence of the seller, the country where the asset is located (source country), or both. India, as a developing economy, has robust provisions to tax capital gains arising from assets situated within its territory, especially from non-residents. CA Final students must grasp the intricate details of these provisions, including specific sections for non-residents and the overriding effect of DTAAs.

Residential Status and its Impact on Capital Gains

The residential status of an assessee is the primary determinant of the scope of total income taxable in India, including capital gains.

• Resident and Ordinarily Resident (ROR): Taxable on global income, including capital gains, irrespective of source or situs of asset.
• Resident but Not Ordinarily Resident (RNOR): Taxable on capital gains accruing or arising in India, or received in India, or from a business controlled in India/profession set up in India. Capital gains from foreign assets (not connected to Indian business/profession) are generally not taxable.
• Non-Resident (NR): Taxable only on capital gains that accrue or arise in India, or are deemed to accrue or arise in India, or are received in India or deemed to be received in India. This is where source rules become paramount.

Source Rules for Capital Gains (Section 9)

Section 9 of the Income Tax Act, 1961, defines income deemed to accrue or arise in India. For capital gains, the key provision is Section 9(1)(i).

Section 9(1)(i): All income accruing or arising, whether directly or indirectly, through or from any business connection in India, or through or from any property in India, or through or from any asset or source of income in India, or through the transfer of a capital asset situated in India, shall be deemed to accrue or arise in India.

Key Point: The phrase "through the transfer of a capital asset situated in India" is crucial for taxing non-residents.

Indirect Transfers (Explanation 5 to Section 9(1)(i))

This is a highly significant and often tested area.

Explanation 5 states that an asset or a capital asset, being any share or interest in a company or entity registered or incorporated outside India, shall be deemed to be situated in India if, at any time during the twelve months preceding the date of transfer, its value, directly or indirectly, is principally derived from assets located in India.

Conditions for applicability:

1. Underlying Asset: The value of the foreign share/interest must be principally derived from assets located in India.
   • "Principally derived" means more than 50% of the value of the assets owned by the foreign company/entity, directly or indirectly, consists of assets located in India.
2. Threshold Exemption: The provision does not apply if the transfer is of shares of a foreign company and the fair market value of Indian assets does not exceed INR 10 Crores.
3. Small Shareholder Exemption: The provision also does not apply to a transfer of shares or interest in a foreign company by a non-resident if:
   • Such shares or interest do not represent, directly or indirectly, more than 5% of the total voting power or share capital or interest in the foreign company/entity; AND
   • Do not entitle the transferor to more than 5% of the income, distribution, or assets in the foreign company/entity; AND
   • The aggregate of the consideration received or receivable by the transferor as a result of such transfer does not exceed INR 10 Crores.

Impact: This explanation allows India to tax gains arising from the transfer of shares of a foreign company, even if the foreign company itself is not an Indian resident, provided its value is substantially derived from Indian assets. This was introduced to address situations like the Vodafone case.

Taxation of Non-Residents on Capital Gains

Once it's established that capital gains accrue or are deemed to accrue in India, the next step is to determine the taxability and applicable rates.

General Provisions (Sections 45, 48)

• Section 45: Charges capital gains to tax.
• Section 48 (Mode of computation):
  • Proviso for Non-Residents (Shares/Debentures in Foreign Currency): Where capital gains arise from the transfer of shares or debentures of an Indian company acquired by a non-resident in foreign currency, the capital gains are computed by converting the cost of acquisition and sale consideration into the same foreign currency (in which the shares/debentures were acquired). The gain so computed in foreign currency is then reconverted into Indian Rupees at the average telegraphic transfer buying rate on the date of transfer. This neutralizes the effect of currency fluctuation on the cost of acquisition.
  • Formula for Section 48 Proviso:
    $\text{Capital Gain (in INR)} = \left( \text{Sale Consideration (in FC)} - \frac{\text{Cost of Acquisition (in FC)} \times \text{Average TTBR at Sale}}{\text{Average TTBR at Acquisition}} \right) \times \text{Average TTBR at Sale}$
    Where TTBR = Telegraphic Transfer Buying Rate
  • No Indexation Benefit: The benefit of indexation (under the second proviso to Section 48) is generally not available to non-residents for capital assets covered by the first proviso (shares/debentures acquired in foreign currency) and for certain other specified assets (e.g., shares of a company not listed on a recognised stock exchange). However, indexation is available for other capital assets (e.g., immovable property) transferred by non-residents.

Specific Tax Rates for Non-Residents

Non-residents are subject to specific, often concessional, tax rates on certain types of capital gains. These rates are usually applied on a gross basis (without deduction of expenses other than cost of acquisition) and without the benefit of Chapter VI-A deductions.

• Section 111A (Short-Term Capital Gains - STCG):
  • On transfer of equity shares, units of equity-oriented mutual fund, or units of a business trust.
  • Transaction is chargeable to Securities Transaction Tax (STT).
  • Tax Rate: 15% (plus surcharge and cess).
• Section 112A (Long-Term Capital Gains - LTCG):
  • On transfer of equity shares, units of equity-oriented mutual fund, or units of a business trust.
  • Transaction is chargeable to STT.
  • Tax Rate: 10% on gains exceeding INR 1,00,000 (plus surcharge and cess).
• Section 112 (Other Long-Term Capital Gains - LTCG):
  • For unlisted shares or other capital assets (where indexation is not available or not opted for).
  • Tax Rate: 20% (with indexation benefit, if applicable) OR 10% (without indexation benefit, if opted for, for listed securities other than those covered by 112A). For unlisted securities, it's generally 10% without indexation or 20% with indexation.

Special Provisions for Certain Non-Residents

• Section 115AD (FIIs/FPIs):
  • Applicable to Foreign Institutional Investors (FIIs) and Foreign Portfolio Investors (FPIs).
  • STCG (other than covered by 111A): 30%
  • LTCG (other than covered by 112A): 10%
  • STCG (covered by 111A): 15%
  • LTCG (covered by 112A): 10% on gains exceeding INR 1,00,000.
  • No deduction under Section 48 (except cost of acquisition) and no Chapter VI-A deductions.
• Section 115ACA (Gains from GDRs):
  • Gains from transfer of Global Depository Receipts (GDRs) purchased in foreign currency by an employee of an Indian company or its subsidiary.
  • Tax Rate: 10% (LTCG) or 15% (STCG).
• Section 115AB (Offshore Funds):
  • Gains from transfer of units of a mutual fund or specified company purchased in foreign currency by an offshore fund.
  • Tax Rate: 10% (LTCG) or 15% (STCG).

Withholding Tax (TDS) on Capital Gains (Section 195)

Any person responsible for paying to a non-resident any sum chargeable to tax in India (including capital gains) must deduct tax at source at the rates in force. This is a critical compliance requirement. The payer must obtain a lower TDS certificate from the Assessing Officer if the actual tax liability is lower than the prescribed rates.

Double Taxation Avoidance Agreements (DTAA) and Capital Gains

DTAAs play a crucial role in international taxation, providing relief from double taxation. As per Section 90(2) of the Income Tax Act, where a DTAA exists, the provisions of the DTAA or the Income Tax Act, whichever is more beneficial to the assessee, shall apply.

Article 13 of OECD/UN Model Convention

Most DTAAs follow the structure of either the OECD Model or the UN Model Convention for Article 13 (Capital Gains). Common rules include:

1. Immovable Property (Article 13(1)): Gains from the alienation of immovable property may be taxed in the Contracting State in which such property is situated (source country).
2. Movable Property of a Permanent Establishment (PE) (Article 13(2)): Gains from the alienation of movable property forming part of the business property of a PE which an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.
3. Ships, Boats, Aircraft, Road Transport (Article 13(3)): Gains from the alienation of ships, boats, aircraft, or road transport vehicles operated in international traffic, or movable property pertaining to the operation of such ships, etc., are usually taxable only in the State where the enterprise has its effective management.
4. Shares (Article 13(4)): This is often the most contentious area.
   • Shares deriving value from immovable property: Many treaties allow the source country to tax gains from alienation of shares of a company if, at any time during the 365 days preceding the alienation, more than 50% of its assets consist of immovable property situated in that source country. This is similar to India's domestic indirect transfer rule, but with specific thresholds.
   • Other shares: For shares not covered by the above, the right to tax often rests solely with the State of residence of the alienator. However, some treaties (e.g., India's DTAAs with Mauritius, Singapore, Cyprus prior to amendments) historically provided for residence-based taxation for all shares, leading to treaty shopping concerns.
5. Other Property (Article 13(5)): Gains from the alienation of any property other than that mentioned above are generally taxable only in the Contracting State of which the alienator is a resident.

Treaty Override and GAAR

• Treaty Override: While DTAAs generally override domestic law to the extent they are more beneficial, India has introduced provisions like Explanation 5 to Section 9(1)(i) and the General Anti-Avoidance Rule (GAAR) to counter treaty abuse and ensure taxation of certain transactions.
• GAAR (Section 95 to 102): GAAR provisions can be invoked if an arrangement is deemed an 'impermissible avoidance arrangement' (e.g., lacking commercial substance, entered into for main purpose of obtaining tax benefit). If GAAR applies, the tax benefit under the DTAA can be denied.
• Limitation of Benefits (LOB) Clause: Many DTAAs now include LOB clauses to prevent treaty shopping, requiring the taxpayer to meet certain conditions (e.g., minimum expenditure, active business, bona fide residency) to claim treaty benefits.

Practical Considerations & Compliance

• Tax Residency Certificate (TRC): A non-resident claiming DTAA benefits must furnish a TRC from their country of residence (Section 90(4)).
• Form 10F: Along with TRC, certain details (e.g., address, tax identification number) must be furnished in Form 10F.
• Advance Ruling: Non-residents can seek an advance ruling from the Authority for Advance Rulings (AAR) on specific tax questions related to capital gains, providing certainty.
• Compliance for Indirect Transfers: Valuation rules (Rule 11UA) and reporting requirements (Form 3CEB) apply to indirect transfers, requiring detailed disclosures.
• Capital Gains Account Scheme: Non-residents can also avail exemption under Section 54, 54F, etc., by depositing the sale proceeds in the Capital Gains Account Scheme.

Common Mistakes & CA Exam Tips

• Ignoring Residential Status: Always start by determining the residential status of the assessee. This dictates the scope of taxable income.
• Incorrect Source Rule Application: Misinterpreting Section 9, especially Explanation 5 for indirect transfers, is a common error.
• DTAA vs. Act: Forgetting to apply the 'more beneficial' rule (Section 90(2)). Always compare tax liability under domestic law and DTAA.
• Indexation for Non-Residents: Incorrectly applying or denying indexation benefit. Remember the proviso to Section 48 for shares/debentures acquired in foreign currency and the general rule for other assets.
• Specific Rates: Confusing tax rates for FIIs/FPIs (Section 115AD) with general non-resident rates (Sections 111A, 112, 112A, 115AD).
• Withholding Tax: Overlooking the Section 195 implications for payments to non-residents.
• GAAR/LOB: Not discussing GAAR or LOB clauses where treaty shopping or abuse is implied in a case study.
• Practice Tip: Solve numerical problems involving different types of assets (listed shares, unlisted shares, immovable property) and different non-resident categories (individual, FII, foreign company) under both domestic law and DTAA scenarios.

Key Takeaways

• Residential status is foundational to determining taxability of capital gains.
• Section 9(1)(i) and its Explanation 5 (indirect transfers) are critical for establishing source in India.
• Non-residents have specific computation rules (Section 48 proviso) and concessional tax rates (Sections 111A, 112, 112A, 115AD).
• DTAAs (Article 13) provide relief from double taxation, but the 'more beneficial' rule applies.
• GAAR and LOB clauses are anti-abuse provisions to be considered.
• Compliance requirements like TRC, Form 10F, and TDS (Section 195) are essential.

Practice Questions

Test your understanding with these exam-style questions. Model answers are provided for self-assessment. These are designed to simulate CA Final written answer requirements.

Short Form Questions (Conceptual & Numerical)

Q1. Explain the concept of 'indirect transfer' as per Explanation 5 to Section 9(1)(i) of the Income Tax Act, 1961. What are the conditions for its applicability and the exemptions provided?

Model Answer:
Explanation 5 to Section 9(1)(i) deems an asset or capital asset, being any share or interest in a company or entity registered or incorporated outside India, to be situated in India if, at any time during the twelve months preceding the date of transfer, its value, directly or indirectly, is principally derived from assets located in India. 'Principally derived' means more than 50% of the value of the foreign company's assets consist of Indian assets.

Conditions for applicability:

1. Transfer of shares/interest in a foreign company/entity.
2. Value of such shares/interest is principally derived from Indian assets.

Exemptions:

1. If the fair market value of Indian assets does not exceed INR 10 Crores.
2. Small shareholder exemption: If the transferor's shares/interest do not represent more than 5% of voting power/share capital/interest AND do not entitle to more than 5% of income/distribution/assets AND aggregate consideration does not exceed INR 10 Crores.

Q2. Mr. A, a non-resident, sold unlisted shares of an Indian company on 15th July 2024 for USD 1,00,000. He had acquired these shares on 1st April 2020 for USD 60,000. The average telegraphic transfer buying rates were: on 1st April 2020: INR 70/USD; on 15th July 2024: INR 83/USD. Compute the capital gains taxable in India for Mr. A, assuming no DTAA benefit is claimed.

Model Answer:
As per the first proviso to Section 48, for non-residents transferring shares/debentures of an Indian company acquired in foreign currency, capital gains are computed by converting cost and sale consideration into the same foreign currency.

Sale Consideration in FC = USD 1,00,000
Cost of Acquisition in FC = USD 60,000

Capital Gain in FC = Sale Consideration in FC - (Cost of Acquisition in FC * (Average TTBR at Sale / Average TTBR at Acquisition))
Capital Gain in FC = USD 1,00,000 - (USD 60,000 * (83 / 70))
Capital Gain in FC = USD 1,00,000 - (USD 60,000 * 1.1857)
Capital Gain in FC = USD 1,00,000 - USD 71,142
Capital Gain in FC = USD 28,858

Capital Gain in INR = Capital Gain in FC * Average TTBR at Sale
Capital Gain in INR = USD 28,858 * INR 83/USD = INR 23,95,214

This will be taxable as Long-Term Capital Gain (assuming holding period > 24 months for unlisted shares) at 20% under Section 112 (without indexation benefit as per the proviso to Section 48).

Q3. Discuss the interaction between the provisions of the Income Tax Act, 1961, and a Double Taxation Avoidance Agreement (DTAA) with respect to capital gains. Refer to relevant sections.

Model Answer:
Section 90(2) of the Income Tax Act, 1961, provides that where the Central Government has entered into a DTAA with any country, the provisions of the Act shall apply to the assessee to the extent they are more beneficial to the assessee. This is known as the 'more beneficial rule'.

Therefore, for capital gains, a non-resident assessee can choose to be governed either by the provisions of the Income Tax Act or by the provisions of the DTAA, whichever results in a lower tax liability. For instance, if a DTAA provides for residence-based taxation of shares (i.e., only the country of residence can tax the gain), and the domestic law (e.g., Section 9(1)(i) Explanation 5) seeks to tax it in India, the assessee can claim treaty benefit if it's more beneficial, subject to anti-abuse provisions like GAAR or LOB clauses in the treaty itself. To claim DTAA benefits, the non-resident must furnish a Tax Residency Certificate (TRC) and Form 10F as per Section 90(4) and 90(5).

Case Studies (Comprehensive Scenarios with Full Solutions)

Case Study 1: Taxation of Unlisted Shares by a Non-Resident with DTAA Application

Mr. B, a resident of Country X (with which India has a DTAA), purchased 10,000 unlisted shares of Alpha Ltd., an Indian company, on 1st May 2022 for INR 50 per share. He sold these shares on 1st September 2024 for INR 120 per share. Assume the DTAA between India and Country X states that 'Gains from the alienation of shares other than those deriving value principally from immovable property may be taxed only in the Contracting State of which the alienator is a resident.' The shares of Alpha Ltd. do not derive value principally from immovable property. Mr. B provides a valid TRC and Form 10F. Assume the cost inflation index (CII) for FY 2022-23 is 331 and for FY 2024-25 is 360.

Requirements:
(a) Compute the capital gains taxable in India as per the Income Tax Act, 1961.
(b) Determine the taxability of capital gains considering the DTAA provisions.
(c) Advise Mr. B on his final tax liability in India.

Model Solution:

(a) Capital Gains as per Income Tax Act, 1961:

• Sale Consideration: 10,000 shares * INR 120/share = INR 12,00,000
• Cost of Acquisition: 10,000 shares * INR 50/share = INR 5,00,000
• Holding Period: May 2022 to September 2024 (> 24 months for unlisted shares) -> Long-Term Capital Gain.
• Indexed Cost of Acquisition: INR 5,00,000 * (CII 2024-25 / CII 2022-23) = INR 5,00,000 * (360 / 331) = INR 5,43,791
• Long-Term Capital Gain (LTCG): INR 12,00,000 - INR 5,43,791 = INR 6,56,209
• Tax Liability (under IT Act): LTCG on unlisted shares is taxable at 20% under Section 112.
  Tax = 20% of INR 6,56,209 = INR 1,31,242 (plus applicable surcharge and cess).

(b) Taxability considering DTAA provisions:

• The DTAA between India and Country X states that 'Gains from the alienation of shares other than those deriving value principally from immovable property may be taxed only in the Contracting State of which the alienator is a resident.'
• Since the shares of Alpha Ltd. do not derive value principally from immovable property, as per the DTAA, the capital gains are taxable only in Country X (Mr. B's country of residence).
• India, as the source country, loses its right to tax this gain under the DTAA.

(c) Advice to Mr. B on final tax liability in India:

• As per Section 90(2) of the Income Tax Act, 1961, where a DTAA exists, the provisions of the Act or the DTAA, whichever is more beneficial to the assessee, shall apply.
• In this case, the DTAA is more beneficial as it grants exclusive taxation rights to Country X, resulting in no tax liability in India for Mr. B.
• Mr. B must ensure he has a valid Tax Residency Certificate (TRC) and has filed Form 10F to claim this DTAA benefit.

Case Study 2: Indirect Transfer and FPI Taxation Scenario

Omega Inc., a company incorporated in USA (a country with which India has a DTAA), holds 60% shares of Delta Corp., a company incorporated in Singapore. Delta Corp. in turn holds 80% shares of Gamma Ltd., an Indian company. The fair market value of assets of Gamma Ltd. located in India is INR 500 Crores. The total assets of Delta Corp. are INR 600 Crores (including its investment in Gamma Ltd.). Omega Inc. sells its entire stake in Delta Corp. to a third-party buyer for USD 150 Million on 1st July 2024. Omega Inc. is a registered FPI in India. The DTAA between India and USA has an Article 13(4) which states that 'Gains from the alienation of shares of a company, the assets of which consist directly or indirectly principally of immovable property situated in a Contracting State, may be taxed in that State.' The DTAA does not specifically address indirect transfers of non-immovable property assets.

Requirements:
(a) Analyze if the transaction by Omega Inc. constitutes an 'indirect transfer' taxable in India as per Explanation 5 to Section 9(1)(i).
(b) If taxable, compute the capital gains and the applicable tax rate under the Income Tax Act, 1961, assuming cost of acquisition for Omega Inc. in Delta Corp. is USD 100 Million.
(c) Discuss the applicability of the DTAA in this scenario, considering Omega Inc. is an FPI.
(d) What compliance requirements would Omega Inc. need to fulfill?

Model Solution:

(a) Analysis of 'Indirect Transfer' as per Explanation 5 to Section 9(1)(i):

• Omega Inc. is transferring shares of Delta Corp., a foreign company (Singapore). The value of Delta Corp. is derived from its assets, including its investment in Gamma Ltd., an Indian company.
• Value of Indian assets (Gamma Ltd.) = INR 500 Crores.
• Total assets of Delta Corp. = INR 600 Crores.
• Percentage of value derived from Indian assets = (INR 500 Crores / INR 600 Crores) * 100 = 83.33%. This is more than 50%, so the value of Delta Corp. is 'principally derived' from assets located in India.
• The fair market value of Indian assets (INR 500 Crores) exceeds the INR 10 Crores threshold for exemption.
• The small shareholder exemption does not apply as Omega Inc. holds 60% of Delta Corp., which is more than the 5% threshold.
• Conclusion: Yes, the transfer of shares of Delta Corp. by Omega Inc. constitutes an 'indirect transfer' and is deemed to be situated in India as per Explanation 5 to Section 9(1)(i), making the capital gains taxable in India.

(b) Computation of Capital Gains and Applicable Tax Rate:

• Sale Consideration: USD 150 Million
• Cost of Acquisition: USD 100 Million
• Capital Gain in USD: USD 150 Million - USD 100 Million = USD 50 Million
• Conversion to INR: Assuming an exchange rate of INR 83/USD (illustrative), Capital Gain = USD 50 Million * INR 83/USD = INR 415 Crores.
• Applicable Tax Rate: Omega Inc. is a registered FPI. Capital gains arising from the transfer of securities (including shares) are covered under Section 115AD.
  • Assuming the holding period for the shares of Delta Corp. is more than 12 months (for listed securities, which is the general FPI investment type, or >24 months for unlisted shares if Delta Corp. is treated as unlisted for this purpose), it would be Long-Term Capital Gain.
  • LTCG for FPIs (other than those covered by Section 112A) is taxable at 10% under Section 115AD.
  • Tax Liability = 10% of INR 415 Crores = INR 41.5 Crores (plus applicable surcharge and cess).
    (Note: If the holding period was 12 months or less, it would be STCG taxable at 30% under Section 115AD, as it's not STT-paid listed equity.)

(c) Applicability of DTAA:

• The DTAA between India and USA has Article 13(4) which allows source-country taxation only for shares deriving value principally from immovable property. The assets of Gamma Ltd. (and thus Delta Corp.) are not necessarily immovable property (they are just 'assets located in India').
• Since the DTAA does not specifically address indirect transfers of non-immovable property assets, and India's domestic law (Explanation 5 to Section 9(1)(i)) specifically brings such gains to tax, the provisions of the Income Tax Act, 1961, would apply. The DTAA does not offer a more beneficial position in this specific scenario.
• Furthermore, given the structure, GAAR provisions could potentially be invoked if the arrangement is deemed an 'impermissible avoidance arrangement', though the primary taxation here is under Explanation 5.

(d) Compliance Requirements:

• Tax Deduction at Source (TDS): The buyer of Delta Corp. shares would be required to deduct tax at source under Section 195 on the payment to Omega Inc., as the capital gains are chargeable to tax in India. Omega Inc. could apply for a lower TDS certificate if applicable.
• Income Tax Return: Omega Inc. would need to file an income tax return in India disclosing the capital gains and paying the tax.
• Form 3CEB: As per Rule 114DB, reporting requirements for indirect transfers apply. Omega Inc. (or the Indian entity whose shares derive value) would need to furnish information in Form 3CEB.
• TRC and Form 10F: Omega Inc. should have a valid TRC and Form 10F, though in this case, the DTAA may not offer a benefit.

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References & Further Reading

• Income Tax Act, 1961 (Sections 9, 45, 48, 90, 111A, 112, 112A, 115AD, 115ACA, 115AB, 195)
• Income Tax Rules, 1962 (Rule 11UA, Rule 114DB)
• Double Taxation Avoidance Agreements (DTAAs) - specific country treaties and OECD/UN Model Conventions (Article 13)
• ICAI Study Material / RTPs / MTPs for CA Final Paper 4 (Direct Tax)
• CBDT Circulars and Notifications related to international taxation and capital gains

Last Updated: July 2026 | Prepared by Kartavvya CA Expert Team (aligned with latest ICAI syllabus & Ind-AS)

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