beps in action – current developments · seattle company claimed in telephone calls with...

BEPS in Action – Current Developments

CA T P Ostwal

CONTENTS

1. DIVERTED PROFITS TAX

2. REPORT ON AGGRESSIVE TAX PLANNING TECHNIQUES

3. EU DIRECTIVES

3

Diverted Profits Tax(informally known as "Google tax")

3M/s T. P. Ostwal & Associates (Regd.)7th November 2015

Trigger for ‘Diverted Profits Tax’


& many more…

ANATOMY OF INCOME SHIFTING(BASE EROSION)

Tax Havens

They really pay it?Let’s find out!

A hugeTax Avoidance

Practice

Standard

Corporation Tax

UK’s

For instance

24%**Prior to 2012(Presently 20%)

Year: 2011

Uk Turnover

Profit before tax

Tax paid

Tax as % of turnover

£20.7m Loss

£32.9m Loss

£13.9m Loss

£0 No tax paid

A look deeperLet’s have

Case Study

Starbucks

United Kindom

First opening: 1998

Stores: 735

Sales*: ₤ 3bn

*reported (Total Sales until year 2012)

Tax paid: ₤ 8.6m

Tax as % of sales:0.3

United Kindom

In the last 5 years*,Starbucks paid in

UK ₤ 0corporation tax

*from 2007 to 2012

They report losses in UK, all financial reports to HM Revenue & Customs being

this way

US executives of the Seattle company claimed in telephone calls with investors, transcripts of which have been seen by

the ‘The Guardian ‘(UK Newspaper), that the

UK business was profitable

while


The contradictions highlight legal tax-avoidance tactics used by multinational companies by loading UK subsidiaries with debts from other parts of the business based in countries with lower tax thresholds

Admission of immoral practice?

After 5 years of not paying any corporation tax, Starbucks finally “woke up”!

In 2013 they paid ₤10m, promising to pay another ₤10m in 2014.

By the way,Do you know the last app released by Apple?

Public outrage

� UK House of Commons Committee of Public Accounts � Public hearings on tax avoidance by

multinational companies (Starbucks,Amazon, Google and the Big-4Accountancy Firms).

� US Senate Permanent Subcommittee on Investigations� Offshore Profit Shifting and the U.S. Tax

Code (Apple Inc.)

“We are not accusing you of being illegal, we are accusing you of being immoral.”- Margaret Hodge (Chair of the Public Accounts Committee)


Pressure on countries with bank secrecy laws


Domestic anti-avoidance trends

� Introduction of General Anti-Avoidance Rules (GAARs)� Two key-elements in most GAARs are: (1) the artificial nature of a transaction; and (2)

the presence of a tax avoidance motive.

� Countries that have implemented GAARs include: Australia, Belgium, Canada, China and recently the United Kingdom.

� India had proposed in 2010 to introduce a GAAR. Implementation of that GAAR deferred to April 2017.

� Introduction of Specific Anti-Avoidance Rules (SAARs)� Examples of SAARs include: CFC legislation, thin capitalization rules and exit charges.

� SAARs targeted at hybrid entities and hybrid instruments in Denmark and the Netherlands.

� SAARs targeted at indirect transfer rules.


Treaty anti-avoidance trends

� An increasing number of tax treaties contain comprehensive andspecific anti-abuse rules - for e.g. Limitation of Benefit (LOB)Clause.

� Under OECD and UN Model Commentaries � comprehensiveLOB clauses and other anti-avoidance rules.

� Tax treaties for non double taxation not permitted


22

Diverted Profits Tax - Overview



• UK diverted profits tax announced at Autumn Statement on 3 December 2014

• In great haste, became a law on 26 March 2015

• Applicable from 1 April 2015

• Tax will be charged at a rate of 25% on diverted profits relating to UK activity

• Stated policy objective: ‘counteract contrived arrangements used by large groups

that result in the erosion of the UK tax base’



• New tax, not corporation tax

• Outside corporation tax self-assessment

• HMRC view that the tax will be outside the UK’s existing doubletax treaty obligations

• Creditable overseas?


25

Scope of Diverted Profits Tax


Scope of Diverted Profits Tax

• Applies in two distinct situations:

1. Foreign company has artificially avoided having a taxable presence in theUK

2. UK company, or UK permanent establishment, has transacted with a low-taxed entity that lacks economic substance

• Requirement for activity (people) in the UK

• Does not apply to:

� Small or medium sized enterprises

� Situations with ‘only’ loan relationships?


Artificial avoidance of UK PE

M/s T. P. Ostwal & Associates (Regd.)7th November 2015

Artificial avoidance of a UK PE

• An entity (person) is 'carrying on activity in the UK in connection withsupplies of goods or services' made by a foreign company to UK customers;and

• 'It is reasonable to assume' that the UK activity is ‘designed’ so that theforeign company is not carrying on a trade through a UK PE

• Where there is either (or both):

� tax avoidance (motive) or

� a ‘mismatch' (a reduction in tax paid combined with a lack ofsubstance)

• Exemption where UK sales < £10 million



Tax avoidance

• The main purpose, or one of the main purposes, of thearrangements is to avoid the charge to UK tax

• Applied objectively giving consideration to full context and facts



Mismatch

• ‘Material provision’ (broadly a transaction or series of transactions) madebetween the foreign company and another connected party;

• the provision results in an effective tax mismatch between the connectedparties; and

• there is insufficient economic substance



Effective tax mismatch• The provision creates either an increase in expenses for which a deduction hasbeen claimed or a reduction in income that would otherwise have been taxed

• There is a reduction in taxes paid, whether in the UK or elsewhere (‘the taxreduction’)

• Exclusion:

� tax reduction less than 20% of the tax that would have been paid (80% paymenttest)

• Tax reduction could result from:

� different rates of tax, operation of a relief, exclusion of any amount from a charge totax, or otherwise



Insufficient economic substance

Either

� the financial benefit of the tax reduction is greater than any other financialbenefit referable to the transaction, or series of transactions;

or

� the contribution of economic value of the functions or activitiesperformed by staff of the entity is less than the value of the financialbenefit of the tax reduction� Management of outsourcing to third parties� counts towards contribution

Management of outsourcing to group companies� does not count


33

Examples and consequences



Section 2 - Example 1Sales & Marketing Subsidiary – Avoidance of PE



Section 2 - Example 1

What might this mean?

� Sales to the UK:

–by fully fledged distributors?

–under commissionaire arrangements?

–in other situations?

� Requirement for activity (people) in the UK



Section 2 - Example 2IP Holding Companies – Entities lacking economic substance


37

Transactions involving lack of economic substance


Sec. 3 - Re-characterization of intra-group transactionsinvolving a lack of economic substance

• ‘Material Provision’ made between UK company and connectedparty (may or may not be UK resident);

• Results in effective tax mismatch between UK company andconnected party;

• The insufficient economic substance condition is met


Examples and consequences


Sec. 3 - Re-characterization of intra-group transactions involving a lack of economic substance

Section 3 – Example 1



Section 3 – Example 1

What might this mean?

• Interaction with transfer pricing rules

• Two-sided analysis needed for transactions with low tax territorieso Where the economic activity is taking place?o How it is priced?

• Complexity where group parties contribute to activities managed by low taxterritory



Company AParent

Company B(Non UK Resident)

Company C(low tax)

UK PE

Assume the facts are the same as those inexample 1, except that the UK activity iscarried on through a UK permanentestablishment of Company B rather than aUK resident company.

The rules at Section 4 ensure the sameresult follows as in example 1, with similaranalysis to arrive at the taxable divertedprofits.

Section 3 - Example 2 – Involvement of entities or transactions lacking economic substance, extended to a UK PE by Section 4



Section 3 - Example 3 - Applying

UK Co 3rd PartyJointly

develops new IP

IP Co(Low Tax)

A group decision is made to establish a new connected company in a low tax jurisdiction (IP Co) andfunds are made available to IP Co to acquire the IP which is subsequently licensed to UK Co

Will DPT apply in this case?



Section 3 - Example 4 – Not Applying

UK Co

IP Co(Low Tax)

Develops and Holds IP

Europe Co1

Europe Co2

Europe Co3

Europe Co4

3rd Party

Licences IP


Calculation of the diverted profits tax


Calculation of the diverted profits tax – initial charge

Initial charge:

� Best judgement estimate by HMRC

� Presumption that inflated expenses create the tax mismatch �

disallowance of 30% of the expenses in calculating diverted profitstax

� No requirement to consider arm’s length position but based onfacts and circumstances


Calculation of the diverted profits tax – ultimate charge

Ultimate charge:

� Taxable diverted profit is amount that would be just and reasonable to assume that itwould be the chargeable profit had there been a UK PE

o leads to negation of effects of excessive expenses flowing through to low-taxjurisdictions without adequate substance

� Taxable diverted profit is amount due if arm’s length principles were applied

o substitution of alternative provision for actual provision

� Credit given for UK, overseas or withholding tax suffered on profits


Next Steps


� New legislation intentionally broad based and has novel compliance and chargingprovisions that may drive small restructurings and greater transparency for a widerange of companies in addition to those groups where an incremental charge is likelyto arise

� Groups will need to assess how the DPT will apply to their current arrangements

� Many groups may wish to consider whether restructuring is appropriate

� In the current tax environment, there may be an increase in the number of APAsbeing sought, in order to reduce some of the uncertainty associated with these rules

� Groups may wish to monitor the progress of the rules and guidance through theconsultation process as well as the reaction of other countries to the rules (eitherunilaterally or through the OECD BEPS process)

Next Steps


Issues


� The DPT purports to be a new and separate tax so that the UK can impose the DPT

without any concern for its existing treaty network.

� However, the UK's double tax treaties also generally apply to all "identical or

substantially similar taxes" to UK income tax, corporation tax and capital gains tax.

� The DPT might not be UK corporation tax, but is it a substantially similar tax?

� Will the DPT survive if a foreign company (or foreign government) challenges it on

the basis that it is subject to an existing double tax treaty?

� How will UK HMRC apply DPT if there is already an APA agreed?

Is DPT compatible with EU Law?


Action 6 - Preventing the granting of treaty benefits in inappropriate circumstances


Preventing the granting of treaty benefits in inappropriate circumstances

� Treaty abuse and treaty shopping identified as one of the most important sources of BEPSconcerns

� Three pronged approach recommended to address treaty abuse and shopping arrangements

Design rules to preventgranting of treatybenefits in inappropriatecircumstances

Tax treaties not intendedto be used to generatedouble non-taxation

Identification of tax policyconsideration – requiredbefore entering into a taxtreaty

� Treaty shopping

“Treaty shopping” generally refers to arrangements through which a person who is not aresident of one of the two Contracting States that concluded a tax treaty may attempt toobtain benefits that the treaty grants to residents of these States


REPORT ON AGGRESSIVE TAX PLANNING TECHNIQUES


Action 12 - Disclosing Aggressive Tax Planning Arrangements


Action 12 – Disclosing aggressive tax planning arrangements

Key Points:� Tax authorities worldwide face challenge of lack of timely, comprehensive and

relevant information on aggressive tax planning which can be addressed bymandatory disclosure rules (‘MDR’)

� Early access to information provides opportunity to quickly respond to tax risks

o Informed risk assessments, audits, changes to legislations/regulations, etc may becarried out

� Countries free to choose whether to introduce MDR or not – not mandatory tointroduce

� Where countries choose to adopt � flexibility provided for balancing country’s needfor timely information with compliance burdens for tax payers



Key Points (Contd..):

� Guidance provided for implementation of MDR to capture international taxschemes which have a material tax revenue risk in the reporting jurisdiction

• Emphasis provided to focus more on BEPS related risks rather than general taxplanning risks arising from such international tax schemes

• Such schemes should require domestic tax payer to disclose when he becomesaware/ ought to have been aware of the cross-border BEPS outcome of thearrangement

o The taxpayer should make reasonable inquiries of the cross-border BEPS outcomes atthe time of entering into such schemes



Key Points (Contd..):

� The Joint International Tax Shelter Information and Collaboration Network(JITSIC Network) of OECD Forum on Tax Administration to be used as aninternational platform for sharing information between tax administrations• aims is to enable enhanced co-operation, collaboration and implementation of more effective

information exchange between tax administrations under mandatory disclosure regimes.

� Forum on Tax Administration (FTA) on 24 October 2014, Dublin, Ireland

“We are taking a significant step forward in global tax co-operation. We have agreed a strategy forsystematic and enhanced co-operation between our tax administrations, based on existing legal instruments,that will allow us to quickly understand and deal with global tax risks whenever and wherever they arise.Along with the strategy, we have created a new international platform called the JITSIC Network to focusspecifically on cross border tax avoidance, which is open to all FTA members on a voluntary basis. This newnetwork integrates the existing cooperation amongst some of us into the larger FTA framework.”



Key Points (Contd..):� Advantages over other disclosures:

� Increased transparency

� Information received early on aggressive or abusive tax planning schemes

• MDR often requires disclosure before returns are filed, in case of tax abusive schemes

� Acts as deterrence for implementation of potentially aggressive schemes

� Early identification of taxpayers including promoters of abusive schemes posing BEPS risks

• They may think twice about entering into such schemes if it has to be disclosed

• Countries can elect who is responsible to disclose – taxpayer or promoter or both

• If promoter responsible to disclose � should disclose when scheme/ related information is made

available to the tax payer

• If taxpayer responsible to disclose � should disclose at the time of implementation of the scheme


Action 13 - Transfer Pricing Documentation and Country-by-Country (CbC) reporting Action 13 - Transfer Pricing Documentation and Country-by-Country (CbC) reporting


Key elements of the CbC implementation package

� Final Report in line with September 2014 report on Transfer PricingDocumentation and Country-by-Country Reporting

� New TP documentation rules that will encourage transparency andcontribute to tackling BEPS.

� Requirement for MNC’s to provide “all relevant governments withneeded information on the global allocation of income, economicactivity and taxes paid among countries according to a commontemplate”.



� Three-tiered standardized approach to TP documentation:

1. A “master file” containing high level information regarding MNE’s globalbusiness operations and TP policies

� to be delivered directly to local tax administration

2. A “local file” containing specific and material TP information for each countryof operation

� to be delivered directly to local tax administration

3. A high level CbC Report containing information relating to global allocation ofMNE’s profits, tangible assets, income tax paid, etc together with indicators ofthe location of economic activity within the multinational group

� to be filed in jurisdiction of tax residence of ultimate parent entity and sharedbetween jurisdictions via automatic exchange of information


BEPS impact in UK – Action 13

Draft regulations for CbC reporting released by UK Government on 5

October 2015 for technical consultation � to implement Action 13 of

OECD’s BEPS project

o These regulations broadly reflect Final OECD Action Plan and make specific

reference to model legislation


Other countries such as Germany, Brazil and Spain have also initiated changes in its regulations to implement Actions 12 and 13 of OECD’s BEPS Project


Key Points of UK’s draft CbC regulations:

� Applicable to accounting periods starting on or after 1 January 2016.

� Applicable to MNEs with a UK tax resident ultimate parent and group consolidated revenues of £586m or more in the preceding financial year;

� Report will follow the template form set by OECD

� Report to be filed electronically within 12 months of the end of the accounting period.



Key Points of UK’s draft CbC regulations (Contd..):

• Provision present for groups with a non UK tax resident parent company tonominate a UK tax resident company to be the ‘Surrogate Parent Entity’ and filethe group CbC report in the UK in certain defined circumstances.

• No provision for a mandatory filing in UK for UK subsidiaries of overseas residentparent companies � if UK does not receive a CbC report under the intergovernment sharing mechanism.

• Penalties prescribed for failure to file, for filing inaccurate CbC report and forfailing to comply with requests for information to enable HMRC to assess theaccuracy of the filing � ranging from £300 to £3,000 with daily penalties forcontinued failure to provide information.


BEPS impact in India - Action 13

What do we expect

� Adoption of 3 tier documentation structure by Indian Revenue authorities

� Increased compliance cost and burden on taxpayers

� Indian Revenue authorities may expect that the Master File and CbC report for all

companies operating in India should be filed locally

� As per OECD guidance the Master File and CbC Report should be used only for risk

assessment procedures, but there may be a temptation to use it for allocation of

revenue and profits based on functions of various group entities rather than only

looking at Indian entities functions.


EU DirectivesEU Directives


European Union Council Directive 2003/48/EU (Savings Taxation Directive)



� One of the legislative instruments of the European Union in its fight against taxfraud and tax evasion

� Provides for systematic co-operation on interest income among the taxauthorities of Member States, helping them to collect taxes due to them by theirresidents

� Requirement for member countries to report interest income paid to anindividual beneficial owner resident in another member State.

� Ensures the availability of information (or a consistent share of tax revenue from thoseMember States, or non-EU jurisdictions, that still provide cooperation in the form of awithholding tax) to national tax authorities on interest and similar savings incomereceived by their residents from paying agents (e.g. banks, investment funds and otherfinancial institutions) established in other Member States



� Entered into force on 1 July 2005

� In 2010, the Directive produced following results:

� A total amount of interest payments of 11.4 billion euros (2009: 12.1 billion) wasmade subject to exchange of information among national tax authorities in the EU;

� 504.8 million euros (2009: 547.3 million) of withholding tax was paid to theMember States of residence of beneficial owners by those Member States and othercountries that still provide cooperation in the form of a withholding tax thanks tothe Directive.

� Directive proven to have clear preventative effect � encourages honestreporting of income by taxpayers



�Amendment to Directive 2003/48/EU

� EU Council Directive 2014/48/EU of 24 March 2014 amended the Directive 2003/48/EU

� Member States to adopt by 1 January 2016

� Objective of the amendment is to:

� reinforce the existing rules

� Safeguard against circumvention of earlier Directive by using an interposed legalentity or arrangement (such as trust, etc) located in a country outside the EU whichdoes not ensure the effective taxation of this legal entity/arrangement on all of itsincome from financial products covered by the earlier Directive

• Reason � Directive 2003/48/EU applied only to interest payments made for immediate benefitof individuals resident in EU




�Objective of the amendment is to (contd..):� Safeguard against circumvention of earlier Directive by using an interposed legal

entity or arrangement (trust, etc) located in an EU country.

� Extend the scope of the earlier Directive to include financial products which present characteristics similar to receivables (such as securities with a fixed/guaranteed rate of return, certain life insurance products), but which are not legally classified as such;

� Take into account, inter-alia, interest and other equivalent income from investment funds - received within and outside of the EU, irrespective of their legal form


European Union Council Directive 2011/16/EU(Administrative cooperation in the field of

taxation)


� A novel step by EU which is triggered by FATCA, OECDCRS for AEOI

� A step towards free flow of information – of a veryhighly sensitive, very private information – across borders

� Aimed at improving transparency � in line withdevelopments in the OECD and its work on BEPS

European Union Council Directive 2011/16/EU(Administrative cooperation in the field of taxation)


� Council Directive 2011/16/EU of 15 February 2011 � establishes new rules and procedures forthe cooperation between EU countries with a view to exchanging information that is relevant tothe administration and enforcement of national laws in the field of taxation.

� W.e.f. 1 January 2015, mandatory automatic exchange of “available information” in respect ofcertain categories concerning taxable periods as from 1 January 2014:

� Income from employment� Director’s fees� Life insurance products� Pensions� Ownership of and income from immovable property

� European Commission’s proposal to further extend the scope of the EU Directive � The list ofcategories may be extended to include “other categories and items, including royalties”.

� EU Member States not at liberty to engage in ‘fishing expeditions’ or to request information thatis unlikely to be relevant to the tax affairs of a given taxpayer.




EU Finance ministers in first week of October 2015 met and agreed to includeautomatic exchange of information on cross-border tax rulings and APAswithin the scope of Directive

� Trigger for inclusion of rulings � Luxembourg Leaks (or LuxLeaks) - financial scandalrevealed by International Consortium of Investigative Journalists (ICIJ) in November 2014

� Finalization of the directive is expected by the end of 2015, with transposition into thenational law of the EU member states by 1 January 2017

� Automatic exchange of cross-border rulings & APAs issued over last 5 years coveredo Commission’s earlier proposal � last 10 years



�Amendment to Directive 2011/16/EU (Contd..)� For rulings issued before 1 January 2017, the following rules would apply:

o Information on rulings/APAs issued, amended or renewed between 1 January 2012and 31 December 2013 would have to be exchanged if the rulings/APAs were stillvalid on 1 January 2014

o Information on advance rulings/APAs issued, amended or renewed between 1January 2014 and 31 December 2016 would have to be exchanged, even if they are nolonger valid when the directive comes into effect.

o Member states would be able to (but would not be obligated to) exclude from automaticexchange, rulings/APAs concerning SMEs (i.e. companies with an annual netturnover of less than EUR 40 million at a group level) if such rulings/APAs wereissued, amended or renewed before 1 April 2016.

� However, this exemption would not apply to SMEs engaged mainly in financial orinvestment activities.



EU Action Plan for Fair and Efficient Corporate Taxation



� European Commission adopted an Action Plan for Fair and EfficientCorporate Taxation in the EU on 17 June 2015.

� The Action Plan sets to reform the corporate tax framework in the EU, inorder to tackle tax abuse, ensure sustainable revenues, strengthen the SingleMarket for businesses and promoting jobs, growth and investment inEurope.

� Collectively, aim is to significantly improve corporate tax environment in EU,making it fairer, more efficient and more growth-friendly.

� The measures complement the work carried out in the OECD/G20 BEPSProject



� 5 key areas for Action identified:

1. Re-launching the Common Consolidated Corporate Tax Base (CCCTB)2. Ensuring fair taxation where profits are generated3. Creating a better business environment4. Increasing transparency5. Improving EU coordination

� Top–30 pan-EU list of non-co-operative tax jurisdictions across the world(includes Mauritius, BVI, Guernsey, Cayman Islands) publishedo Aim is to have a common EU approach to defining and reacting to third country non-

cooperative tax jurisdictions



“…all companies – big or small, local or global – must pay a fair share of tax wherereal economic activity is taking place and where their profits are actually made.”

- Margrethe Vestager, European Commissioner for Competition

“The European Commission’s initiative is another major step towards internationalco-operation in the fight against tax evasion and avoidance. The political impetusand support for establishing a fairer international tax system is overwhelming.Initiatives like the Commission’s action plan will help foster a co-ordinatedimplementation of the measures developed in the course of the OECD/G20 BEPSProject. A globalised economy needs single global standards.”

- OECD Secretary-General Angel Gurría


Way ForwardWay Forward

Way Forward

� Tax and Morality debate: Here to stay

� BEPS – Game changer for the Revenue and the Taxpayers

� Domestic anti-abuse tax legislations being adopted globally

� Substance and Transparency – part of life

� Corporate Tax Rates may be reducing, but the base is increasing

Companies to not only adhere to compliance regulations but also review theiroperating structures in various jurisdictions, as countries are expected toincorporate the BEPS action points in their local regulations


Global Crackdown on Tax Evasion gathers pace

• To tackle the menace of tax evasion, several governments have offered taxevaders a last chance to own up to undeclared accounts

• Ahead of receiving the bank data through AEOI, many governmentsseems to successfully pressing citizens over repatriation of offshorefunds.

• Dozens of countries will begin to exchange tax files automatically in 2017as part of a co-ordinated global crackdown on evasion, exposing non-compliant taxpayers to an unprecedented risk of prosecution.

• Infamy around the aggressive tax planning by MNEs has influencedmany countries (including Ireland, UK, USA) to reform their tax regimesin the “shadow” of the OECD project on BEPS.


Global Crackdown on Tax Evasion gathers pace

List of Countries which have offered ‘Voluntary Disclosure Opportunity’

• India has introduced several voluntary disclosure schemes - staring from the VoluntaryDisclosure Scheme, 1951 (Tyagi Scheme) to Kar Vivad Samadhan Scheme, 1998 to the veryrecent “one time compliance scheme” under Black Money Act - there have been morethan 12 such voluntary disclosure schemes till date

• South Africa offered a voluntary disclosure facility till August 12• UK will close its schemes by the start of next year• France expected its crackdown on offshore income to raise €2bn euros, similar to theamount raised in 2014.

• Germany’s voluntary disclosure programme was used by almost 40,000 taxpayers in 2014• Even in Belgium, 22,000 people came forward voluntarily to disclose undeclaredaccounts

• US too has been actively probing since 2009• Recently, Russia also passed a law with a voluntary disclosure programme for all Russiancitizens, irrespective of their tax residency


Question to ponder!!

What happens tothe protection oftaxpayer’sfundamentalrights??


TAX PAYER’S RIGHTS!!?

ANY QUESTIONS

17-10-2015T.P.Ostwal & Associates (Regd.) 88

THANK YOU

T. P. Ostwal & AssociatesCHARTERED ACCOUNTANTS

4th Floor, Bharat House,

104 Mumbai Samachar Marg,

Fort, Mumbai-400001.

Tel No.: +91-22-40693900

Fax No.: +91-22-40693999

Mobile:+919004660107

Email: [email protected]

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