On June 6, 2024 on the website of the Court of Justice of the European Union (CJEU) an opinion of Advocate General Collins in Case C-243/23, Belgische Staat / Federale Overheidsdienst Financiën versus L BV, ECLI:EU:C:2024:468, was published.
Introduction
By this request for a preliminary ruling, the Hof van Beroep te Gent (Court of Appeal, Ghent, Belgium) asks the Court whether deductions of input VAT paid in respect of extensive renovation works carried out on a property used for both professional and residential purposes are subject to an adjustment period of five years on the basis that the works constitute ‘capital goods’, or are subject to an adjustment period of 15 years on the ground that those works are ‘immovable property acquired as capital goods’ for the purposes of Article 187 of the VAT Directive.
The dispute in the main proceedings, the request for a preliminary ruling and the procedure before the Court
12. L BV, the respondent in the main proceedings, is a law firm. It uses 60% of a property for professional purposes (offices and ancillary accommodation) and the remaining 40% for private purposes (residence of the law firm’s owner). From 2007 to 2015, L BV caused to have carried out extensive works on that property. They included the construction of an archive cellar, a new glass annex with offices and a lift shaft; stripping the building; installing new insulation and cladding; redoing pipes and connections for gas, water and electricity; remaking walls, floors and ceilings; adjusting the roof; inserting new dormer windows; and installing two roof terraces.
13. On 1 January 2014, Belgium ceased to exempt the provision of legal services from the charge to VAT. L BV accordingly registered for VAT from that date. A consequence of registration for persons who provided legal services was that they could deduct, by way of adjustments, the VAT that they had paid on capital goods acquired prior to registration, provided that the applicable adjustment period had not expired. When it calculated its liability to VAT, L BV sought to deduct the input VAT it had paid on the works that it had carried out on the property in reliance upon the extended period of 15 years applicable to ‘immovable property acquired as capital goods’ by Belgian law.
14. Following a tax audit, the Belgische Staat/Federale Overheidsdienst Financiën (Belgian State/Federal Public Finance Service, Belgium; ‘the tax authority’), the appellant in the main proceedings, found that L BV had committed several infringements of Belgian law with respect to its liability to VAT for the period between 1 January 2014 and 30 September 2015. For the 15-year adjustment period to apply to works to convert buildings under Belgian law, they had to result in a new first occupation of the property for the purposes of Article 12(1) of the VAT Directive. The tax authority was of the view that the works L BV had caused to have carried out on the property did not meet that requirement. Treating those works as capital goods, it applied a five-year adjustment period to the deduction of input VAT with respect to them.
15. The tax authority made a demand of L BV for payment of unpaid VAT, fines and interest. On 10 October 2018, L BV contested that demand by way of proceedings before the rechtbank van eerste aanleg Oost-Vlaanderen, afdeling Gent (Court of First Instance, East Flanders, Ghent Division, Belgium). By judgment of 10 March 2020, that court found partly in favour of L BV. The tax authority and L BV respectively appealed and cross-appealed that judgment to the Hof van Beroep te Gent (Court of Appeal, Ghent). In the context of that appeal the Hof van Beroep te Gent (Court of Appeal, Ghent) decided to stay the proceedings and to refer the following questions to the Court of Justice for a preliminary ruling:
‘(1) Do Articles 187 and 189 of [the VAT Directive] preclude legislation such as that at issue in the main proceedings (namely Article 48(2) and Article 49 WBTW [(Belgian VAT Code)], read in conjunction with Article 9 KB No 3 of 10 December 1969, relating to the deduction facility for the application of value added tax), according to which the extended adjustment period (of 15 years) in the case of the renovation of an existing building is applied only if, after completion of the works, on the basis of the criteria under national law, there is a ‘new building’ within the meaning of Article 12 of the aforementioned Directive, whereas the useful economic life of a substantially renovated building (which, however, on the basis of the administrative criteria under national law does not qualify as a ‘new building’ within the meaning of the aforementioned Article 12) is identical to the useful economic life of a new building, which is considerably longer than the period of five years referred to in the aforementioned Article 187, which is shown, inter alia, by the fact that the works carried out are depreciated over a period of 33 years, which is also the period over which new buildings are depreciated?
(2) Does Article 187 of [the VAT Directive] have direct effect, so that a taxable person who has carried out works on a building without those works leading to the renovated building being classified as a ‘new building’ within the meaning of Article 12 of that directive on the basis of criteria under national law, but where those works have a useful economic life which is identical to that of such new buildings to which a 15-year adjustment period does apply, may rely on the application of the 15-year adjustment period?’
16. L BV, the Belgian Government and the European Commission submitted written observations. At the hearing of 13 March 2024, those parties presented oral argument and replied to the Court’s questions.
Conclusion
45. The Advocate General therefore proposes that the Court answer the questions referred for a preliminary ruling by the Hof van Beroep te Gent (Court of Appeal, Ghent, Belgium) as follows:
(1) Articles 187 and 189 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax must be interpreted as precluding legislation according to which an extended adjustment period within which input VAT payable or paid with respect to ‘immovable property acquired as capital goods’ may be adjusted applies to supplies of services connected to immovable property, such as works carried out for the renovation or conversion of a building.
(2) The first sentence of Article 187(1) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax has direct effect.
Legal framework
European Union law
Directive 2006/112/EC (‘VAT Directive’)
2. Under Article 12 of the VAT Directive:
‘1. Member States may regard as a taxable person anyone who carries out, on an occasional basis, a transaction relating to the activities referred to in the second subparagraph of Article 9(1) and in particular one of the following transactions:
(a) the supply, before first occupation, of a building or parts of a building and of the land on which the building stands;
(b) the supply of building land.
2. For the purposes of paragraph 1(a), “building” shall mean any structure fixed to or in the ground.
Member States may lay down the detailed rules for applying the criterion referred to in paragraph 1(a) to conversions of buildings and may determine what is meant by “the land on which a building stands”.
…
3. For the purposes of paragraph 1(b), “building land” shall mean any unimproved or improved land defined as such by the Member States.’
3. Article 47 of the VAT Directive deals with the supply of services connected with immovable property. It provides:
‘The place of supply of services connected with immovable property, including the services of experts and estate agents, the provision of accommodation in the hotel sector or in sectors with a similar function, such as holiday camps or sites developed for use as camping sites, the granting of rights to use immovable property and services for the preparation and coordination of construction work, such as the services of architects and of firms providing on-site supervision, shall be the place where the immovable property is located.’
4. Article 135(1)(j) provides:
‘1. Member States shall exempt the following transactions:
…
(j) the supply of a building or parts thereof, and of the land on which it stands, other than the supply referred to in point (a) of Article 12(1);
…’
5. By virtue of Article 167 of the VAT Directive:
‘A right of deduction shall arise at the time the deductible tax becomes chargeable.’
6. According to Article 168 of the VAT Directive:
‘In so far as the goods and services are used for the purposes of the taxed transactions of a taxable person, the taxable person shall be entitled, in the Member State in which he carries out these transactions, to deduct the following from the VAT which he is liable to pay:
(a) the VAT due or paid in that Member State in respect of supplies to him of goods or services, carried out or to be carried out by another taxable person;
….’
7. Under Article 184 of the VAT Directive:
‘The initial deduction shall be adjusted where it is higher or lower than that to which the taxable person was entitled.’
8. By virtue of Article 187 of the VAT Directive:
‘1. In the case of capital goods, adjustment shall be spread over five years including that in which the goods were acquired or manufactured.
Member States may, however, base the adjustment on a period of five full years starting from the time at which the goods are first used.
In the case of immovable property acquired as capital goods, the adjustment period may be extended up to 20 years.
2. The annual adjustment shall be made only in respect of one-fifth of the VAT charged on the capital goods, or, if the adjustment period has been extended, in respect of the corresponding fraction thereof.
The adjustment referred to in the first subparagraph shall be made on the basis of the variations in the deduction entitlement in subsequent years in relation to that for the year in which the goods were acquired, manufactured or, where applicable, used for the first time.’
9. Article 189 of the VAT Directive provides:
‘For the purposes of applying Articles 187 and 188, Member States may take the following measures:
(a) define the concept of capital goods;
(b) specify the amount of the VAT which is to be taken into consideration for adjustment;
(c) adopt any measures needed to ensure that adjustment does not give rise to any unjustified advantage;
(d) permit administrative simplifications.’
10. Article 190 of the VAT Directive provides:
‘For the purposes of Articles 187, 188, 189 and 191, Member States may regard as capital goods those services which have characteristics similar to those normally attributed to capital goods.’
Belgian law
11. At the time material to the main proceedings, Belgian law subjected deductions of VAT paid in respect of ‘capital goods’ and ‘services which have characteristics similar to those normally attributed to capital goods’ to a five-year adjustment period. An adjustment period of 15 years applied in respect of deductions of VAT paid on ‘immovable property acquired as capital goods’. Deductions of VAT paid in respect of conversions of buildings that resulted in a new first occupation of the property within the meaning of Article 12(1) of the VAT Directive came within the second category.
From the assessment of the Advocate General
A. The parties’ observations
17. The Belgian Government observes that, under Article 187 of the VAT Directive, Member States are free to determine whether to extend the adjustment period applicable to ‘immovable property acquired as capital goods’ up to 20 years and, under Article 189 thereof, to define the concept of ‘capital goods’. Belgium applies a 15‑year adjustment period to the acquisition or construction of new buildings and a five-year adjustment period to all other capital goods. New buildings for those purposes include works on a building that result in it being converted to such an extent that it acquires the characteristics of a ‘new building’ for the purposes of Article 12 of the VAT Directive. The tax authority determines if that is the case by reference to national law. Where those criteria are not met, the tax authority treats such works as capital goods and applies the five-year adjustment period.
18. L BV and the Commission take the view that the works that gave rise to the main proceedings should be considered as ‘immovable property acquired as capital goods’ and that the extended adjustment period of 15 years under Belgian law should apply thereto. In order to respect the principle of fiscal neutrality, where a Member State extends the adjustment period in respect of ‘immovable property acquired as capital goods’, that extended period must apply to all immovable property acquired as capital goods that share the same characteristics. That includes circumstances where a building acquires a useful economic life similar to that of a new building following significant renovation works.
B. Analysis
1. The first question
(a) The adjustment system
19. The right of deduction under Article 167 of the VAT Directive is an integral part of the VAT system. It is designed to relieve traders of the entire burden of the VAT payable or paid in the course of all of their economic activities that are subject to VAT. By this means, the common system of VAT ensures that all economic activities subject to VAT, whatever their purpose or results, are taxed in a neutral way. The right to deduct is exercisable immediately in respect of all VAT charged on input transactions. In order to establish a close and direct relationship between the right to deduct input VAT and the use of the goods and services concerned for taxable output transactions, Articles 184 to 192 of the VAT Directive establish a system to facilitate the adjustment of input VAT deductions. That system aims to ensure the accuracy of deductions and hence the neutrality of the tax burden.
20. The parties in the proceedings before the Court agree that, for the purposes of the adjustment period for deductions of input VAT, the works L BV had carried out are ‘capital goods’. The dispute between them is as to whether those works are also ‘immovable property acquired as capital goods’, thereby obtaining the benefit of the longer adjustment period. In general, taxpayers seek to adjust input VAT deducted over as short a period as possible. An unusual feature of this reference is that the taxable person, L BV, seeks the application of the longer adjustment period to its circumstances.
(b) Do the ‘capital goods’ referred to in Article 187 of the VAT Directive include ‘immovable property’?
21. The various language versions of the term ‘immovable property acquired as capital goods’ in Article 187 of the VAT Directive are not uniform. The French and Dutch language versions refer to ‘biens d’investissement immobiliers’ and ‘onroerende investeringsgoederen’ respectively. The English and German language versions speak of ‘immovable property acquired as capital goods’ and ‘Grundstücken, die als Investitionsgut erworben wurden’. One possible reading of the French and Dutch language versions is that the faculty Article 189 confers on Member States to define the concept of ‘biens d’investissement’ and ‘investeringsgoederen’ includes a power to define the concept of ‘biens d’investissement immobiliers’ and ‘onroerende investeringsgoederen’. The English and German language versions do not, however, readily lend themselves to that interpretation. On the contrary, they clearly suggest that since the provision applies to ‘immovable property’ ‘acquired as’ ‘capital goods’, ‘immovable property’ and ‘capital goods’ are distinct and, therefore, autonomous legal concepts.
22. A divergence between various language versions of a provision of EU law requires that that provision be interpreted by reference to the general scheme and purpose of the rules of which it forms part.
23. The Commission’s written observations are of some assistance in that context. The initial proposal for the Sixth Directive provided for an adjustment period of five years with respect to capital goods. It made no mention of ‘immovable property acquired as capital goods’. The possibility to extend the adjustment period for up to 10 years in the case of ‘immovable property acquired as capital goods’ arose out of some Member States’ concerns that the adjustment period of five years was insufficiently long, for example, with respect to purchases of land. That debate tends to show that, at that time, the concept of capital goods included immovable property. In order to provide for a longer adjustment period with respect to immovable property, that concept had to be separated out from that of capital goods and treated as an autonomous notion. As a consequence, a hybrid concept, one part of which EU law defined exclusively (immovable property) and one part of which national law could define within certain parameters (capital goods), came into existence. It is therefore unsurprising that all of the parties that participated at the hearing agreed that the concept of ‘immovable property’ in the VAT Directive is an autonomous concept of EU law. The permission that Article 189 of the VAT Directive gives to the Member States to define the ‘concept of capital goods’ thus does not extend to a power to define ‘immovable property’, even where such property is acquired as a capital item.
(c) Capital goods
24. In its judgment in Verbond van Nederlandse Ondernemingen, the Court first observed that the term ‘capital goods’ was part of a provision of Community law that did not refer to the law of the Member States in order to determine its meaning and its scope. Its interpretation therefore could not be left to the discretion of each Member State. The Court proceeded to hold that capital goods covered goods used for the purposes of some business activity distinguished by their durable nature and their value such that the costs of their acquisition were normally written off over several years and not treated as current expenditure. The Court has since held that those considerations apply, mutatis mutandis, to the special system for the adjustment of deductions relating to capital goods in Article 20 of the Sixth Directive, notwithstanding that, by Article 20(4) thereof, Member States may define the concept of capital goods. It follows that Member States do not enjoy an unfettered discretion when they exercise the power to define capital goods that Article 189 of the VAT Directive affords to them. In that context, it is worth mentioning that since account is taken of the text, context and objectives of a provision of EU law in determining its meaning and scope, the definition of ‘capital goods’ in one provision of EU law is not necessarily the same as that in another. Whilst Member States have a certain discretion when they define ‘capital goods’ for the purposes of Article 187 of the VAT Directive, for the reasons set out in point 23 of the present Opinion, that discretion does not extend to allowing them to define immovable property acquired as such goods.
(d) Immovable property acquired as capital goods
25. The VAT Directive defines neither ‘immovable property’ nor ‘immovable property acquired as capital goods’. Nor does it afford Member States the possibility to define those concepts in a manner akin to that which Article 189 of the VAT Directive permits in respect of capital goods. The Court’s case-law accordingly requires that the meaning and scope of those terms is to be given an autonomous and uniform interpretation that takes into account the context of that provision and the purpose of the legislation in which it appears.
26. Council Implementing Regulation (EU) No 1042/2013 of 7 October 2013 amending Implementing Regulation (EU) No 282/2011 as regards the place of supply of services introduced a definition of ‘immovable property’ for the purposes of the application of the VAT Directive. Under that definition, ‘immovable property’ includes any building or construction fixed to or in the ground above or below sea level which cannot be easily dismantled or moved; any item that has been installed and makes up an integral part of a building or construction without which the building or construction is incomplete, such as doors, windows, roofs, staircases and lifts; and any item, equipment or machine permanently installed in a building or construction which cannot be moved without destroying or altering the building or construction.
27. While Implementing Regulation No 1042/2013 applied from 1 January 2015, the provisions that define ‘immovable property’ and ‘supply of services connected with immovable property’ only applied from 1 January 2017. According to recital 18 to Implementing Regulation No 1042/2013, the introduction of the concept of immovable property, which sought to ensure a uniform tax treatment by Member States of supplies of services connected with immovable property, could have had a considerable impact on Member State legislative and administrative practices. To facilitate a smooth transition its introduction was delayed.
28. The Court has held that a conferral of implementing powers upon the Commission requires that institution to provide further detail in relation to the content of a legislative act in order to ensure its uniform implementation in all Member States. An implementing measure must, therefore, comply with the essential aims of the legislative act which it is expected to clarify and be necessary or appropriate for the uniform implementation of that act without supplementing or amending it, even as to non-essential elements. The Court has also held that Implementing Regulation No 282/2011, which Implementing Regulation No 1042/2013 amends, is in the nature of a codifying measure.
29. From this case-law, I draw the conclusion that, in the absence of any indications to the contrary, Implementing Regulation No 1042/2013 complies with the essential aims of the VAT Directive and both codifies and clarifies its provisions. That implementing regulation is also necessary or appropriate for the uniform implementation of the VAT Directive without supplementing or amending its provisions, even as to non-essential elements. Notwithstanding the moratorium on the application of the provisions of Implementing Regulation No 1042/2013 that define ‘immovable property’ and ‘supply of services connected with immovable property’ until 2017, I advise the Court that it can take them into account when it interprets Article 187(1) of the VAT Directive.
30. The Court also provides guidance as to the content of the concept of immovable property in the interpretations it has delivered on other provisions of the VAT Directive. It has deemed land, buildings and parts of buildings to be ‘immovable property’. Caravans, tents, mobile homes, and light-framed leisure dwellings, being movable, are not. Buildings made from prefabricated components, with a concrete base erected on concrete foundations sunk into the ground, have been considered as immovable property, despite the fact that eight persons working over the course of ten days could dismantle them for subsequent reuse. The Court observed that, in order to constitute immovable property, those buildings did not need to be inseverably fixed to, or in, the ground. Land and water-based moorings for boats have been regarded as immovable property where the water-covered area of land is clearly delimited and cannot be moved. A permanently immobilised houseboat fixed by attachments to the bank and bed of a river and exclusively used as a restaurant and discotheque has also been treated as immovable property.
31. Are works, such as those in respect of which L BV seeks to deduct input VAT, ‘immovable property’? The examples of ‘immovable property’ in the Court’s case-law on the interpretation of the VAT Directive indicate that the notion of tangibility – the item in question can be seen and touched – and that of its fixation to the ground lie at the core of that concept. Article 13b of Implementing Regulation No 282/2011 refers to installed items that make up an integral part of a building or construction without which the building or construction is incomplete. Neither the Court’s case-law, nor Article 13b of Implementing Regulation No 282/2011, refer to the processes or services whereby those items are installed in, or make up part of, a building.
32. It follows that the works with respect to which L BV seeks to deduct input VAT paid are not ‘immovable property acquired as capital goods’ for the purposes of Article 187(1) of the VAT Directive. What, then, did L BV acquire in the circumstances described in the order for reference?
(e) Supply of services connected to immovable property
33. The VAT Directive contains a number of provisions relating to the supply of services connected with immovable property. Article 47 thereof provides that the place of supply of services connected with immovable property shall be the location of the property. In the context of this reference for a preliminary ruling, it is noteworthy that that provision brings the preparation and coordination of construction work, such as the services of architects and of firms providing on-site supervision, within its ambit. Article 199 of the VAT Directive refers to the supply of construction work, including repair, cleaning, alteration and demolition services in relation to immovable property. Those provisions of the VAT Directive thus distinguish between immovable property and services connected to immovable property. The works and the services which are the subject matter of the main proceedings appear to encompass those described in Articles 47 and 199 of the VAT Directive. Article 31a of Implementing Regulation No 282/2011, which provides that services connected with immovable property include the drawing up of plans for a building; the construction of a building on land, as well as construction and demolition work performed on a building; and maintenance, renovation and repair of a building, appears to confirm that interpretation. As point 26 of the present Opinion explains, Article 13b of Implementing Regulation No 282/2011 excludes services provided in connection with immovable property from the definition of immovable property.
34. I further observe that, prior to July 2006, the Sixth Directive did not contain a provision equivalent to Article 190 of the VAT Directive, which explicitly allows Member States to treat as capital goods services which have characteristics similar to those normally attributed to capital goods. Recital 5 of Directive 2006/69 explains the introduction of that measure by emphasising that ‘services with the nature of capital items may be included in the scheme which allows the adjustment of deductions for capital items over the lifetime of the asset, according to its actual use’. It follows from the rationale for that amendment that it was not intended that such services constituted ‘immovable property acquired as capital goods’ for which the Sixth Directive had made special provision.
35. By reason of the foregoing I am of the view that works, such as those which are the subject matter of the main proceedings, are, as Belgium observed at the hearing, a supply or a series of supplies of services connected to immovable property. It follows that, for the purposes of Article 187 of the VAT Directive, L BV acquired services connected to immovable property, which Belgium treats as capital goods, and not ‘immovable property acquired as capital goods’.
(f) Conversions under Article 12 of the VAT Directive
36. In the light of the referring court’s question, I address this issue for the sake of completeness. As a rule, the sale of old buildings is not subject to VAT because of the relative lack of added value that such sales generate. Since a conversion adds value to a building in the same way as its initial construction, the VAT Directive facilitates the taxation of supplies of converted buildings. Article 12(2), read in conjunction with Article 135(1)(j), of the VAT Directive therefore provides that the ‘conversion’ of an ‘old’ building may be assimilated to the supply of a ‘new’ building before first occupation and thereby become subject to VAT.
37. The VAT Directive does not appear to draw a link between Article 12 and Article 135(1)(j) thereof, in so far as they concern ‘conversions’ of buildings, and the concept of ‘immovable property acquired as capital goods’ to which Article 187 thereof refers. Nor does it follow from Article 12 of the VAT Directive, which provides that Member States may lay down detailed rules to treat the supply of a building following a ‘conversion’ as a supply of a building before first occupation, that such conversions are to be considered as ‘immovable property acquired as capital goods’.
38. Since Belgium does not have the power to treat conversions as ‘immovable property acquired as capital goods’, L BV’s and the Commission’s arguments as to that Member State’s failure to observe the principle of fiscal neutrality fall away. In any event, it may be observed that since works carried out for the purposes of renovations or conversions are treated as ‘capital goods’ for the purposes of Article 187 of the VAT Directive, they are subjected to the same five-year adjustment period such that the principle of fiscal neutrality appears to be respected.
39. In the light of all of the above considerations, I propose that the Court answer the first question as follows:
Articles 187 and 189 of the VAT Directive must be interpreted as precluding legislation according to which an extended adjustment period within which input VAT payable or paid with respect to ‘immovable property acquired as capital goods’ may be adjusted applies to supplies of services connected to immovable property, such as works carried out for the renovation or conversion of a building.
2. The second question
40. By its second question, the referring court asks whether Article 187 of the VAT Directive has direct effect so that a taxable person who has carried out works on a building, where those works have a useful economic life identical to that of new buildings, may rely on the 15-year adjustment period that applies to the latter.
41. In the light of my proposed answer to the first question, there is no need to reply to the second question since the latter is based upon a supposition that it is lawful to apply an extended adjustment period to input VAT payable or paid in respect of services connected to immovable property. In the event that the Court does not agree with that analysis, I will address the question as to whether the first sentence of Article 187 has direct effect.
42. According to the Court’s settled case-law, whenever the provisions of a directive appear, so far as their subject matter is concerned, to be unconditional and sufficiently clear and precise, individuals may rely upon them against the State before national courts where the State has failed to implement that directive by the end of the period prescribed or has not done so correctly. When exercising their discretion as to the form or methods for implementing a directive, Member States must exercise that discretion within the limits set out therein.
43. The Court has held that Article 187 of the VAT Directive is binding in nature. The imposition of a requirement to afford an adjustment period for the deduction of input VAT on capital goods enables the avoidance of inaccuracies in the calculation of deductions and unjustified advantages or disadvantages for a taxable person, thereby ensuring the neutrality of the tax burden. As point 24 of the present Opinion makes clear, the discretion Member States enjoy under Article 189 of the VAT Directive to define the concept of ‘capital goods’ for the purposes of applying Article 187 thereof is limited by the Court’s judgment in Verbond van Nederlandse Ondernemingen. In any event, the first sentence of Article 187 of the VAT Directive is not subject to Member States taking measures to define ‘capital goods’, since it is for the Member States to decide whether to adopt such measures. The obligation to afford an adjustment over five years for input VAT paid in respect of capital goods is clear, precise and unconditional. As a result, the first sentence of Article 187 of the VAT Directive fulfils the conditions for direct effect.
44. In the light of the above considerations, I propose that the Court answer the second question as follows:
The first sentence of Article 187(1) of the VAT Directive has direct effect.
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