Employee share plans in Turkey: regulatory overview

A Q&A guide to employee share plans law in Turkey.

The Q&A gives a high level overview of the key practical issues including, whether share plans are common and can be offered by foreign parent companies, the structure and rules relating to the different types of share option plan, share purchase plan and phantom share plan, taxation, corporate governance guidelines, consultation duties, exchange control regulations, taxation of internationally mobile employees, prospectus requirements, and necessary regulatory consents and filings.

To compare answers across multiple jurisdictions, visit the Employee Share Plans: Country Q&A tool.

This Q&A is part of the global guide to employee share plans law. For a full list of jurisdictional Q&As visit www.practicallaw.com/employeeshareplans-guide.

Contents

Employee participation

1. Is it common for employees to be offered participation in an employee share plan?

Employee share plans are relatively new to the Turkish employment market and are therefore not common. However, with the increasing level of foreign investments and market entries into Turkey, employee share plans are likely to become more common in the near future.

 
2. Can employees be offered a share plan where the shares to be acquired are in a foreign parent company?

A foreign parent company can offer foreign securities and capital market instruments to employees of a subsidiary in Turkey (Article 15(c), Decree 32 on the Protection of the Value of Turkish Currency) (Currency Law).

This kind of share sale is subject to Turkish capital markets legislation and requires application to the Capital Markets Board of Turkey (CMB) (see Question 30), unless all of the following apply (Communiqué on Foreign Capital Market Instruments, Depository Receipts and Foreign Investment Funds (VII-128.4)) (Foreign Capital Markets Law):

  • The sale does not take place in Turkey.

  • No transaction that can be defined as a public offering is conducted.

  • The information provided to the employees does not contain any statements that give the impression of a public offering.

 

Share option plans

3. What types of share option plan are operated in your jurisdiction?

There are no established share option plans (see Question 1). Turkish companies can use one of three general structures to offer shares to their employees:

  • Capital increase and issuing new shares. Shares are granted to employees following a capital increase. The pre-emptive rights of current shareholders are restricted, and the employees subscribe to the newly issued shares derived from the capital increase.

  • Share buyback and reissue. The company acquires its own shares, subject to the Turkish Commercial Code (TCC) and related Capital Markets Board (CMB) regulations for public companies, and then transfers the shares to its employees under a plan.

  • Option agreement. This is a fusion of the above two methods. The company and the employee enter into an option agreement. The company grants the employee the right to acquire a certain amount of shares for a fixed range of amounts within a prescribed period. New shares are created by a capital increase, or issued shares are repurchased by the company, and then transferred to the employee under the terms of the option agreement. The financing for the shares is provided by the company or employee.

  • In certain situations, finance assistance opportunities may be available to employees (including advance payments, extensions of loans or a provision of securities to enable employees to purchase new acquisitions of shares from the company). For plans relating to acquisitions of shares, see Question 10.

Grant

4. What rules apply to the grant of employee share option plans?

General rules

There are no specific rules or regulations relating to employee share plans in Turkey. However, there are references to share plans in other pieces of Turkish legislation. In addition to the Currency Law and the Foreign Capital Markets Law (see Question 2) the following rules are likely to apply to employee share plans in Turkey:

  • Article 403, Turkish Code of Obligations (number 6098). Although not specifically referring to the ownership of shares by employees, this provision states that employees can be granted additional interests and benefits aside from their remuneration (salary). This provision may pave the way for phantom share plans in the future (see Question 16).

  • Article 522 to 523, Turkish Commercial Code (TCC)(number 6102). This rule is also enshrined in Article 110 of the Turkish Civil Code. It allows companies to establish trusts, co-operatives and charity funds for its employees. Under this structure, trusts founded by employee contributions can become shareholders in the parent company, allowing the employees to indirectly own certain portions of a parent company's shares.

  • Article 463, TCC. This introduces the possibility of conditional capital increase and makes direct reference to share plans that are executed by companies for the benefit of their employees. In this structure, companies can enter into a capital increase on the condition that the newly issued shares will be granted to the employees.

  • Article 379, TCC. This introduces the possibility for companies to acquire their own shares (up to 10% of the share capital). Accordingly, companies can subscribe to the shares, pay their value and transfer them to their employees as a bonus or premium.

  • Article 380, TCC. This states that a company can provide financial assistance to its employees to enable them to acquire its shares.

Capital increase and issuing new shares

Discretionary/all-employee. The company can increase its share capital either through a public offering of shares (for example, an initial public offering (IPO) or a secondary public offering (SPO)) or it may issue and offer new shares solely to its employees (private placement).

The employer must treat all employees equally, provided there is no justified reason (for example, differences in seniority).

Non-employee participation. In addition to employees, share option plans can be offered to non-employee board members and consultants.

Maximum value of shares. There is not a rule in relation to a maximum value of shares over which options can be granted either on per company or per employee basis. For public companies, private placement opportunities are available (limited to a maximum of 150 employees).

Market value. For private companies, at least nominal value of the shares must be paid. As a general rule, shares can be issued on their market prices for listed companies. Publicly held companies must have a valuation report for the share price. However, the employees can be offered a discounted price up to 20% in an IPO or SPO (Article 27, Communiqué on Sale of Capital Markets Instruments).

Share buyback and reissue

Discretionary/all-employee. See above, Capital increase and issuing new shares.

Non-employee participation. See above, Capital increase and issuing new shares.

Maximum value of shares. All companies can subscribe up to 10% of their shares (Article 379, TCC). This creates a maximum amount which can be offered to employees under the plan. For public companies, private placement opportunities are available (limited to a maximum of 150 employees).

Market value. For private companies, at least nominal value of the shares must be paid. As a general rule, shares can be issued on their market prices for listed companies. Publicly held companies must have a valuation report for the share price.

Option agreement

Discretionary/all-employee. See above, Capital increase and issuing new shares.

Non-employee participation. See above, Capital increase and issuing new shares.

Maximum value of shares. See, Capital increase and issuing new shares and Share buyback and reissue.

Market value. See, Capital increase and issuing new shares and Share buyback and reissue.

 
5. What are the tax/social security implications of the grant of the option?

There are no tax/social security implications on grant.

Vesting

6. Can the company specify that the options are only exercisable if certain performance or time-based vesting conditions are met?

The company can, at its own discretion, specify performance or time-based vesting conditions provided the conditions are not discriminatory, unless there is a justifiable reason (for example, if the vesting conditions relate to seniority).

 
7. What are the tax/social security implications when the performance or time-based vesting conditions are met?

Tax

The Income Tax Law describes employment income as benefits paid in cash, in-kind or other ways, represented by money for services rendered, to persons employed by an employer and working at a certain workplace (Article 61). This definition includes all non-cash benefits provided and payments made (including allowance, compensation, cash indemnity, funds, increase, advance, dues, attendance fee, premium, bonus, reimbursement or under any other names). Payment as a certain percentage of earnings (provided it is not related to an ownership of a company and related to the employment of the concerned personnel) must also be included under this definition and considered as employment income.

The taxable event for employment income is triggered once the employee legally and economically has the right to dispose of the benefit or payment. Income tax is imposed upon exercise on any "spread" on the shares, which is the excess of the fair market value of the shares on the exercise date, over the aggregate exercise price paid.

The benefit (that is, the difference between the shares' price at grant and value at vesting) is subject to withholding tax and must be declared by the Turkish resident company in the withholding tax return (Article 94, Income Tax Law). The income tax rate is applied at progressive rates ranging between 15% and 35%.

Social security

There are no social security implications on vesting.

Exercise

8. What are the tax/social security implications of the exercise of the option?

Tax

Once the option is exercised, any gain realised by the employee is subject to income tax.

The tax base must be (Communiqué No. 282 Income Tax Law):

  • Fair market value of the shares.

  • Transaction value of the shares.

  • Option premium.

Social security

Under Article 80 of the Social Insurance and General Health Insurance Law (numbered 5510) (Law No. 5510), the following are taken into consideration in the calculation of earnings subject to premium:

  • Deserved wages.

  • Premium, bonus and any kind of similar payments made in the concerned month.

  • Amounts paid by the employers for private health insurance and individual retirement system.

  • Payments made to employees in the concerned month in the form of earnings stated above as a result of decisions rendered by administrative bodies and judicial authorities.

It further provides that deserved wages are subject to premium on the month they are granted, whereas other payments are subject to premium on the month they are paid/executed. As a result, social security implication will arise when the share option is exercised.

As at January 2015, employees pay a monthly premium of 14% of the monthly gross salary (plus 1% for unemployment insurance). Employers pay a monthly premium of 19.5% of the monthly gross salary (plus 2% for unemployment insurance). These rates are inclusive of short and long-term risk and general health insurance.

However, if the amount of salary and additional payments (for example, share options) received by employees exceed the social security payment cap (TRY7,809.90 between 1 January 2015 and 30 June 2015 and TRY 8,277.90 between 1 July 2015 and 31 December 2015), the premium amount that must be paid by the employer remains unchanged.

Sale

9. What are the tax and social security implications when shares acquired on exercise of the option are sold?

For capital gains the cost is defined as the amount paid by the seller in the process of purchase including share price. It is possible to increase the cost base using the Producer Price Index if the increase in the index is larger than 10%.

Under the definition in Article 80 of the Income Tax Law, capital gains exemptions apply in case of:

  • Gains derived from the disposal of (Turkish-resident legal entities' shares that are held for more than two years.

  • Gains derived from a sale of shares listed on the Istanbul Stock Exchange and retained for more than one year are not subject to withholding tax (Paragraph 1, temporary Article 67, Income Tax Law).

Article 80 of the Income Tax Law provides an income tax exemption for up to TRY10,600 (for 2015) of capital gains derived in a calendar year, unless derived from the disposal of marketable securities and other capital market instruments, including listed shares. Since this exemption does not apply to a sale of marketable securities, the whole amount of gains derived from the sale of marketable securities is taxed as capital gains, regardless of whether they belong to a Turkish resident or non-resident entity.

The capital gains must be declared by the employees through an annual income tax return and are subject to income progressive income tax rates ranging between 15% and 35%.

Social security

There are no social security implications when shares acquired on exercise of the option are sold.

 

Share acquisition or purchase plans

10. What types of share acquisition or purchase plan are operated in your jurisdiction?

Turkish law does not distinguish between share option and share acquisition plans (see Question 3).

Acquisition or purchase

11. What rules apply to the initial acquisition or purchase of shares?

Discretionary/all-employee. The employer must treat all employees equally, provided there is no justified reason (for example, differences in seniority).

Non-employee participation. In addition to employees, share option plans can be offered to non-employee board members and consultants.

Maximum value of shares. There is not a rule in relation to a maximum value of shares over which options can be granted either on per company or per employee basis in capital increase. With respect to share buyback and reissue, all companies can subscribe up to 10% of their shares (Article 379, TCC). This creates a maximum amount which can be offered to employees under the plan.

For public companies, private placement opportunities are available (limited to a maximum of 150 employees).

Market value. With respect to capital increase, for private companies, at least the nominal value of the shares must be paid. As a general rule, shares can be issued on their market prices for listed companies. Publicly held companies must have a valuation report for the share price. However, the employees can be offered a discounted price up to 20% in an IPO or SPO (Article 27, Communiqué on Sale of Capital Markets Instrument).

With respect to share buyback and reissue, for private companies, at least nominal value of the shares must be paid. As a general rule, shares can be issued on their market prices for listed companies. Publicly held companies must have a valuation report for the share price.

Payment for shares and price

Prices may be paid by the employees for the acquisition or purchase of shares.

 
12. What are the tax/social security implications of the acquisition or purchase of shares?

No taxable event/social security implications arise on acquisition.

Vesting

13. Can the company award the shares subject to restrictions that are only removed when performance or time-based vesting conditions are met?

The company can, at its own discretion, specify performance or time-based vesting conditions provided the conditions are not discriminatory unless there is a justifiable reason (for example, if the vesting conditions relate to seniority).

 
14. What are the tax and social security implications when the performance or time-based vesting conditions are met?

The tax/social security implications are the same as for share option plans (see Question 7).

Sale

15. What are the tax and social security implications when the shares are sold?
 

Phantom or cash-settled share plans

16. What types of phantom or cash-settled share plan are operated in your jurisdiction?

As employee share option plans are uncommon in Turkey, there are currently no specific or preferred types of phantom or cash-settled share plans.

Grant

17. What rules apply to the grant of phantom or cash-settled awards?

Discretionary/all-employee. The employer must treat all employees equally, provided there is no justified reason (for example, differences in seniority).

Non-employee participation. In addition to employees, share option plans can be offered to non-employee board members and consultants.

Maximum value of awards. There is not a rule in relation to a maximum value of shares over which options can be granted either on per company or per employee basis in capital increase. With respect to share buyback and reissue, all companies can subscribe up to 10% of their shares (Article 379, TCC). This creates a maximum amount which can be offered to employees under the plan.

For public companies, private placement opportunities are available (limited to a maximum of 150 employees).

 
18. What are the tax/social security implications when the award is made?

There are no tax/social security implications on the grant of phantom or cash-settled awards. However, a taxable event is triggered at the exercise of the option.

Vesting

19. Can phantom or cash-settled awards be made to vest only where performance or time-based vesting conditions are met?

Phantom share plans are not common practice in Turkey. However, if a phantom share plan is used, the award can be made to vest on the fulfilment of performance or time-based conditions.

 
20. What are the tax/social security implications when performance or time-based vesting conditions are met?

The tax/social security implications are the same as for share option plans (see Question 7).

Payment

21. What are the tax and social security implications when the phantom or cash-settled award is paid out?

No tax/social security implications exist at this stage, since tax and social security obligations only arise when the employee is entitled to claim relevant rights (see Question 20).

 

Corporate governance guidelines, market or other guidelines

22. Are there any corporate governance guidelines, market rules or other guidelines that apply to any of the above plans?

The Capital Markets Board (CMB) Communiqué on Corporate Governance (numbered II-17.1) regulates the principles of corporate governance, which is applicable to publicly held corporations and listed corporations. The employees are among the stakeholders of these corporations. The Communiqué brings high level principles for all stakeholders including employees (for example, rule of equal treatment and prohibition of discrimination among employees). The Communiqué also provides that these corporations can arrange employee stock ownership plans.

 

Employment law

23. Is consultation or agreement with, or notification to, employee representative bodies required before an employee share plan can be launched?

Under employment law, consultation, agreement with or notification to employee representative bodies is not required before an employee share plan is launched. However, the Communiqué on Corporate Governance provides that decisions taken relating to the employees or developments relevant to employees must be notified to the employees or representatives of the employees. The opinion of the syndicate must also be taken while taking such decisions by the publicly held companies or listed companies.

 
24. Do participants in employee share plans have rights to compensation for loss of options or awards on termination of employment?

Participants are entitled to compensation, provided this is stipulated in the share plan.

 

Exchange control

25. How do exchange control regulations affect employees sending money from your jurisdiction to another to purchase shares under an employee share plan?

A transfer of monies for the purpose of purchasing shares in another jurisdiction must be made through a bank or other financial institution (Article 15(d)(ii), Currency Law).

 
26. Do exchange control regulations permit or require employees to repatriate proceeds derived from selling shares in another jurisdiction?

Repatriation of proceeds is permitted under the Currency Law.

 

Internationally mobile employees

27. What is the tax position when an employee who is tax resident in your jurisdiction at the time of grant of a share option or award leaves your jurisdiction before any taxable event affecting the option or award takes place?

For the purposes of Turkish taxation if employee is a non-resident the Turkish tax consequences will depend on type of income and existence of Double Taxation Agreements (DTA). We will not analyse any DTA implications therefore the provisions of DTAs are reserved.

There may be three types of income applicable:

  • Employment income.

  • Capital gains.

  • Dividend income if any dividend is obtained by the employee following the delivery of the shares.

For the income of non-resident real persons to be subject to Turkish income tax, they must be deemed as "Turkish sourced", for example:

  • For non-resident real persons employment income is deemed to be sourced (taxable) in Turkey if the employment is exercised or benefitted in Turkey.

  • For non-resident real persons capital gains is deemed to be sourced (taxable) in Turkey if the transaction is exercised or benefitted in Turkey

  • For dividend income if the capital is invested in Turkey.

The term "benefitted", in relation to employment income and capital gains, refers to when the activity or transaction generating the income is performed or accounted for in Turkey.

"Accounted for" means that a payment is made in Turkey, or if the payment is made abroad, it is recorded in the books in Turkey or is made from the profits of the payer or the person on whose behalf the payment is made in Turkey.

 
28. What is the tax position when an employee becomes tax resident in your jurisdiction while holding share options or awards granted abroad and a taxable event occurs?

In case taxable event occurs the tax implications will be similar to Questions 7, 8 and 9.

 

Securities laws

29. What are the requirements under securities laws or regulations for the offer of and participation in an employee share plan?

Capital increase and issuing new shares

The company can increase its share capital through a public offering of shares (for example, an IPO or SPO). In that case, the employees are a separate investment group together with other investment groups who can subscribe for the new shares.

The company can also issue and offer new shares solely to its employees (private placement). In both cases, the company must decide to increase its share capital and to restrict the pre-emptive rights of current shareholders (by board of directors or by shareholders meeting).

The related Turkish capital market regulations apply to offer of and participation in an employee share plan if it is realised through an IPO or SPO. For an IPO or SPO, following the resolution of capital increase and restriction of pre-emptive rights of current shareholders, the company must apply to Capital Markets Board (CMB) for approval. The company must comply with certain rules and regulations (such as the preparation of a public offering prospectus and circular).

The company can also issue and offer new shares solely to its employees (private placement). In this case, following the resolution of capital increase and restriction of pre-emptive rights of current shareholders, the publicly held company must prepare an issuance document and apply to the CMB for approval as well and subject to restrictions as to transfer of shares by the shareholders and number of employees (that is, up to 150 employees) who can subscribe for the new shares.

Share buyback and reissue

A publicly held company can acquire its own shares if its general assembly authorises its board of directors in this respect (Article 5, CMB Communiqué on Buy-backed Shares (numbered II-22.1)). A publicly held company can reissue the buy-backed shares to its employees (private placement). However, it is subject to restrictions on the transfer of shares by the shareholders and number of employees who can subscribe for those shares. In this case, a publicly held company must prepare an issuance document and apply to the CMB for approval.

 
30. Are there any exemptions from securities laws or regulations for employee share plans? If so, what are the conditions for the exemption(s) to apply?

For public companies in Turkey, if the employee share plan is structured to be realised by a public offering of shares, the general requirements for public offerings apply (see Question 29). If the employee share plan is executed through a private placement, then it is subject to preparing an issuance document and Capital Markets Board (CMB) approval and it is exempted from preparing a prospectus and circular requirement. To qualify as a private placement, the issuance must comply with certain conditions, for example that the offer can only be made to a maximum of 150 employees.

Foreign parent companies offering securities to Turkish employees are exempt from filing and approval of CMB if certain conditions are met (see Question 2).

For private companies, there are specific exemptions from filing and registration with the CMB. If the number of shareholders is less than 500 after the plan is implemented, the company is not required to apply to CMB. In this case, the company will only have to comply with the registration and notification requirements of the trade registries, depending on the capital increase method they adopt (that is, through registered share capital, principal share capital or conditional capital increase).

 

Other regulatory consents or filings

31. Are there any other regulatory consents and filing requirements and/or other administrative obligations for an offer of and participation in an employee share plan?

Employee share plans executed by public companies may also have disclosure requirements under the Communiqué on Public Disclosure of Material Events (numbered II-15.1).

Further, if the employee share plan involves capital increase, the approval of the Ministry of Customs and Trade for the amendment of the articles of association is required as well. In addition, registration with the specific trade registries may be necessary for certain employee share plan transfers (for example, if the transfer involves a capital increase or transfer of shares in limited liability companies).

 
32. Are there any data protection requirements or obligations for an offer of and participation in an employee share plan?

Employees must protect the company's commercial secrets during the employment relationship and are subject to certain confidentiality obligations after the employment relationship is terminated (Article 396, Turkish Code of Obligations).

The TCC does not impose strict confidentiality requirements on shareholders. However, Turkish doctrine accepts (although to a limited degree) the confidentiality obligation of the shareholders. Therefore, employees who become shareholders through an employee share plan are, in principle, under an obligation of confidentiality.

The employer must prepare a personal file for each employee, use the employee's information in accordance with good faith and not disclose such information to third parties (Article 75, Labour Code).

 

Formalities

33. What are the applicable legal formalities?

Translation requirements. Documents must be translated into Turkish. If not, documents are considered null and void and an administrative fine can be imposed.

E-mail or online agreements. It is permissible to conclude an agreement by e-mail or online. However, proving these kinds of agreements can be problematic in practice and therefore concluding agreements electronically is not advisable.

Witnesses/notarisation requirements. Share transfers in limited liability companies must be executed by a notary. However, this obligation does not exist for joint stock companies.

Employee consent. The employee's consent must be obtained in connection with actions required to administer the options or awards.

 

Developments and reform

34. Are there any current trends, developments and reform proposals that have or will affect the operation of employee share plans?

Trends and developments

Employee share plans will probably become more common in the near future due to the increasing level of foreign investments and market entries into Turkey.

Reform proposals

There are currently no proposals for reform.

 

Online resources

Capital Markets Board of Turkey website

Description. Website for the Capital Markets Board of Turkey, in English. Translations are for reference only.

www.cmb.gov.tr/



Contributor profiles

Omer Collak, Partner

Paksoy

T + 90 212 366 47 32
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Professional qualifications. Admitted to the Istanbul Bar

Areas of practice. Capital markets; banking and finance; Islamic finance; corporate and commercial.

Non-professional qualifications. LLB, Marmara University Law School; LLM, Golden Gate University School of Law, San Francisco, California.

Recent transactions

  • Practicing banking and finance with a specific focus on capital markets transactions. Acting for issuers and investment banks in equity, debt and equity-linked instruments in international public offerings, Eurobond offerings, Islamic finance transactions, and private placements.
  • Leading the capital markets practice of Paksoy.
  • Experienced in listed company mergers and acquisitions.
  • Worked as a foreign associate in a California-based law firm, where he worked on corporate law for high-tech and bio-tech companies, prior to joining to Paksoy.

Languages. English.

Professional associations/memberships

  • Member of the International Bar Association.
  • Member of the American Bar Association.
  • Board member of Darussafaka Cemiyeti.

Okkes Sahan, Senior Associate

Paksoy

T + 90 212 366 47 90
F + 90 212 290 23 55
E osahan@paksoy.av.tr
W www.paksoy.av.tr

Professional qualifications. Admitted to the Istanbul Bar

Areas of practice. Banking regulatory; corporate governance; capital markets; banking and finance.

Non-professional qualifications. LLB, Ankara University School of Law; LLM, University of California, Davis.

Recent transactions

  • Experienced in corporate governance, company law, securities and capital market transactions.
  • Formerly legal counsel at the Capital Markets Board of Turkey, providing legal advice to other departments of the Capital Markets Board.
  • Prepared legal opinions on specific issues, represented Capital Markets Board before courts, conducted legal researches related with the issues that the departments faced while implementing the provisions of Capital Market Law.
  • Worked as a member of the working group appointed for drafting a report on legal implications of Turkish Commercial Code to Capital Markets regulations.
  • Worked as a member of the working group drafting the new Capital Markets Law (CML). After the CML was enacted, he worked as a member of the working group drafting the secondary regulations.

Languages. English.

Professional associations/memberships.

  • Capital market activities (advanced level license holder).
  • Derivative instruments license holder.
  • Real estate appraiser.
  • Credit rating specialist.
  • Corporate governance rating specialist.
  • Independent auditor in capital markets.

Baris Kencebay, Senior Tax Counsel/Head of Tax

Paksoy

T + 90 212 366 47 90
F + 90 212 290 23 55
E bkencebay@paksoy.av.tr
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Professional qualifications. MA Finance, Webster University UK

Areas of practice. Tax services (specialised in Banking and Insurance Transaction Tax (BITT), VAT, Resource Utilisation Support Fund (RUSF), stamp duty and other indirect taxes).

Non-professional qualifications. LLB, Bilkent University.

Recent transactions

  • Advising clients in tax aspects and structuring needs of transactions including mergers and acquisitions, banking and finance, and all forms of direct foreign investments.
  • Advising on a wide variety of taxation matters including corporate tax, investment tax, financing tax, real estate tax, VAT, BIIT, RUSF, transfer pricing, expatriate taxation and international tax structuring.
  • Advising for tax litigation and legal disputes involving taxation matters.
  • Working in Paksoy's M&A practice group for structuring issues and tax litigation reviews.
  • Formerly the tax advisor to four of the top seven banks in Turkey which constitute the majority of the sector and has structured some of the largest international investments in real estate, private equity and alike.

Languages. English


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