Our newsletters were published 8 - 10 times per year. They containsummaries on the latest relevant tax developments with extensive links to the relevant (proposals of) laws, memoranda and other background documentation.
| Newsletters | ||
|---|---|---|
| 2006-09 | ||
| "Working for profit" bill adopted by Second Chamber | ||
| MOU on simultaneous audits in the Netherlands and Canada | ||
| Supreme Court rules on minimum holding period participation | ||
| High Court on acquisition costs participation and ECHR | ||
| Other points of interest | ||
| - Tax Plan 2007 submitte | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Case C-290/04, FKP Konzertproduktionen GmbH | ||
| Case C-386/04, Centro di Musicologia Walter Stauffer | ||
| Case C-196/04 Cadbury Schweppes | ||
| Case C-452/04 Fidium Finanz AG | ||
| Case C-470/04 N | ||
| Hot links | ||
| 2006-08 | ||
| Update on major overhaul business income taxation | ||
| Local Court reiterates: Exit tax contravenes good treaty faith | ||
| Dutch/French Code of Conduct on MAP’s | ||
| Other points of interest | ||
| - Consolidated functional currency decree | ||
| - Expired obligations | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Deductibility costs of Turkish participation | ||
| Local Court rules on Dutch Marks & Spencer case | ||
| Dutch dividend tax developments | ||
| Hot links | ||
| 2006-06 | ||
| Bill submitted for major overhaul business income taxation | ||
| Supreme Court misses opportunity in foreign entity classification | ||
| Dutch tax treaty negotiations update | ||
| Other points of interest | ||
| - Participation exemption: intermediate holdco's | ||
| - Treaty qualification of redemption of shares | ||
| - Hierarchy tax exemptions and tax credits | ||
| - Belgian emigration and place of management | ||
| EU RELATED TAX DEVELOPMENTS | ||
| No Dutch dividend tax on 2.25% strategic interest of EU Co’s | ||
| EC Competition fine partially deductible | ||
| No Bosal for third countries (again) | ||
| ECJ Rules in the Conijn Case (C-346/04) | ||
| 2006-05 | ||
| Corporate Income Tax reduced to 25%, dividend tax to 15% | ||
| Bill for new Dutch investment vehicle | ||
| Supreme Court on BV emigration combined with liquidation | ||
| Other points of interest | ||
| - Consolidation and acquisition costs | ||
| - Consolidation and loss from liquidation | ||
| - Loss carry forwards and transfer of shares | ||
| - New 2001 loss limitation rules | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Hot links | ||
| 2006-04 | ||
| Supreme Court: 2210 perpetual qualifies as a loan | ||
| Court rules on debt conversion & participation exemption | ||
| Ministry issues decree on tax transparent investment funds | ||
| High Court on emission costs of securities & interest free loan | ||
| Other points of interest | ||
| - Conversion of legal persons | ||
| - Tax return by SMS | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Supreme Court ask questions re. mutual investment fund regime | ||
| The spirit of Bosal lingers on | ||
| Exit tax: Opinion in the N-case and Local Court ruling | ||
| Hot links | ||
| 2006-03 | ||
| New decree on hybrid entities issued | ||
| High Court rules on residence under tax treaties | ||
| 0% dividend tax to Netherlands Antilles announced | ||
| Other points of interest | ||
| - Supreme Court: Consolidated group request by tax return | ||
| - Two decrees published on delegation of cross border exchange of information | ||
| - Collective decree on tax consequences of converting legal entities | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Keller Holdings GmbH (Case C-471/04) | ||
| CLT-UFA SA (Case C-253/03) | ||
| Hilten van der Heijden (Case C-513/03) | ||
| Hot links | ||
| 2006-02 | ||
| General decree on participation exemption | ||
| Supreme Court rules on tax consolidated groups | ||
| 0% dividend tax to Netherlands Antilles announced | ||
| Other points of interest | ||
| - Dutch/Greek Treaty protocol signed | ||
| - Collective decrees on tax treatment of co-operatives and mutual investment funds | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Two cases on Bosal and third countries | ||
| Amendments to P/S directive implemented into Dutch law | ||
| Supreme Court rules on application of Merger Directive | ||
| Various Courts decide on capital duty | ||
| High Court rules on free movement of workers | ||
| Hot links | ||
| 2006-01 | ||
| Supreme Court rules on treatment Pret Participatif and Titre Subordinée à Duree Indeterminée | ||
| High Court rules on the netting of forwards and futures | ||
| 0% dividend tax to Netherlands Antilles announced | ||
| Ministry reissues decree on interest deduction limitations | ||
| Ministry reissues decree on Trusts & NA private foundations | ||
| Ministry reissues decree on limitations on loss compensation | ||
| 2007 Taxplan discussed in parliament | ||
| Various bills accepted by Dutch First and Second Chambers | ||
| New mutual fund vehicle announced | ||
| Other points of interest | ||
| - Supreme Court: Third loan loss, not part of ruling income | ||
| - Supreme Court: Belgian BBC not resident in Netherlands | ||
| - Supreme Court: Dutch branch Belgian Bank not only financed with debt | ||
| - Real estate transfer tax exemption extended | ||
| - Participations in transparent entities specified per item | ||
| - Market interest rates for valuing long term interest free loans | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Advocate General advises on question of abuse in merger | ||
| Painful omission leads to capital duty | ||
| Decree on dividends to and from Switzerland | ||
| Hot links | ||
| 2005-11 | ||
| Tax Plan 2006 | ||
| Local Court rules on residence Belgian Coordination Center | ||
| Supreme Court rules on 12 year statute of limitations | ||
| Shares in group finance company are portfolio investment | ||
| High Court applies participation exemption to option | ||
| Other points of interest | ||
| - Debt conversion bill discussed in First Chamber | ||
| - Q&Commentaries to the 2006 Corporate Tax Package | ||
| - Supreme Court: Paying exempt gain to third party not deductible | ||
| - Q&Protocol to Dutch/Estonian tax treaty | ||
| - Mutual Agreement procedure with Isle of Man | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Fokus bank hits the Dutch courts | ||
| Ministry publishes overview Dutch cases before ECJ | ||
| Supreme Court decides on Bosal's costs of litigation | ||
| Is Dutch Dividend withholding tax on its way out? | ||
| State Secretary talks about the 2007 Corporate tax regime | ||
| Hot links | ||
| 2005-10 | ||
| 2006 Corporate Tax Package: Capital Duty abolished and top corporate tax rate down to 29.6% | ||
| Supreme Court prevents additional assessment under ruling and determines documents tax authorities may require | ||
| Advocate General opines on banking branches | ||
| Other points of interest | ||
| - Abolishing group financing regime | ||
| - Answers on conversion debt to equity bill | ||
| - AG opinion on Swiss treaty and application Dutch unilateral decree | ||
| - Decree on newly formed subsidiary joining consolidated group | ||
| EU RELATED TAX DEVELOPMENTS | ||
| State Secretary responds to questions on Parent/Subsidiary Directive | ||
| Dutch capital duty cases | ||
| Hot links | ||
| 2005-09 | ||
| Supreme Court decides on US-Dutch tax treaty and the prevention of double taxation | ||
| Q&A published on the 2004 US/Dutch treaty protocol | ||
| Decree on filing electronic requests for dividend tax refunds | ||
| Supreme Court classifies temporary repurchase of shares | ||
| Other points of interest | ||
| - Creditor allows receivable to lapse | ||
| - Q&A Decree on 30% facility | ||
| - Supreme Court: Ruling v Subsequent policy | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Supreme Court rules on capital duty levied from immigrated company | ||
| Hot links | ||
| 2005-08 | ||
| High Court confirms hierarchy between branch exemption and withholding tax credits | ||
| High Court applies loss limitation rules strictly | ||
| VAT decision on cross border lease transactions | ||
| Dutch business responds to planned tax changes 2007 | ||
| Other point of interest | ||
| - Asset mergers against preference shares | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Hot links | ||
| 2005-07 | ||
| Decree on share mergers and dividend tax reissued | ||
| Supreme Court denies application of interest limitation rules | ||
| New figures on Dutch ruling practice issued | ||
| Decree on hybrid entities in Dutch / US relations (BV/CV structures) | ||
| EU RELATED TAX DEVELOPMENTS | ||
| ECJ decides D-Case in favour of government | ||
| Advocate General advises in Hilten van der Heijden | ||
| The Savings Directive | ||
| Hot links | ||
| 2005-04 | ||
| Dutch government publishes proposals for 2007 tax system | ||
| Proposed bill on converting branches to participations | ||
| Dutch / Chinese treaty on air tax in groundbreaking format | ||
| Valuation of bonds acquired above par value | ||
| Supreme Court on treatment of cash settled convertibles | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Foreseeable emigration of BV’s and waiving their pension liabilities | ||
| Bill allows occupational pension policies from other member states | ||
| 2005-03 | ||
| Supreme Court creates clarity on "Reasonable time" for fines | ||
| Debt conversion bill acquires retro-active effect | ||
| Overview of Dutch treaty negotiations | ||
| Abolishment of Dutch capital duty | ||
| Other points of interest | ||
| - Exchange of information treaty with Poland | ||
| - Bill for abolishment group finance company regime | ||
| - Decrease in value shares after acquisition but prior to receipt | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Implementation amended Parent/Subsidiary Directive | ||
| Supreme Court determines that Bosal is not applicable to 3rd countries | ||
| 2005-02 | ||
| Debt conversion bill finally acquires retro-active effect | ||
| Tax inspector ordered to pay Euro 72.000 litigation fees | ||
| New figures on Dutch ruling practice issued | ||
| Other points of interest | ||
| - Parliamentary questions on US/Dutch treaty protocol | ||
| - Unilateral double tax decree not applicable to Swiss treaty | ||
| EU RELATED TAX DEVELOPMENTS | ||
| High Court rules on application Bosal to third countries | ||
| Possible changes of law regarding abuse of legal persons | ||
| Hot links | ||
| 2005-01 | ||
| High Court rules on French hybrid financing instruments | ||
| Convertible bonds qualify for participation exemption | ||
| Dutch industry strongly criticises debt conversion bill | ||
| Tax consolidation does not cause companies to be disregarded for treaty purposes | ||
| Other points of interest | ||
| - Roll over capital gains on shares | ||
| - Capital duty: no asset merger exemption from 2 contributors | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Supreme Court decides on damages in Ascher case | ||
| ECJ decision introduced late in procedure is irrelevant | ||
| Savings Directive extended to Netherlands Antilles | ||
| State Secretary believes Dutch exit taxes are EU compliant | ||
| Dutch group finance company regime abolished | ||
| FII Group litigation case | ||
| Hot links | ||
| 2004-12 | ||
| Decree on entity classification | ||
| Decree on participation exemption and hybrid entities | ||
| Preliminary ruling on deductibility of waived interest | ||
| Dutch international tax Q&A Decree | ||
| NA NV not resident in the Netherlands | ||
| Capital duty Q&A Decree | ||
| Decree on participation exemption and earn-out arrangements | ||
| Other points of interest | ||
| - Third protocol Dutch/German tax treaty | ||
| - Corporate income tax rate 31.5% | ||
| - Two fact finding Courts in tax cases | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Decree on implementation amendments to P/S Directive | ||
| Supreme Court decides in Irish interest free loan case/EU law | ||
| Capital duty exemption for contribution (almost) total equity | ||
| Hot link | ||
| 2004-11 | ||
| Ministerial Decree on Securitisation and profit sharing loans | ||
| Treaty update: New Zealand, Estonia, Lithuania & Sweden | ||
| Waiving of written down receivable is not taxable in NL | ||
| Decree on special employee stock options | ||
| Decree on the expiration of the statute of limitation on debts | ||
| US approves protocol to US/Dutch tax treaty | ||
| Other points of interest | ||
| - Loan to near bankrupt Parent is hidden profit distribution | ||
| - Fishing GmbH resident in the Netherlands | ||
| - Can Limited Partners be so passive that there is no LP? | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Dutch Supreme Court decides on application of Bosal | ||
| Amendments to double tax relief following De Groot | ||
| Advocate General advises in D-Case | ||
| EFTA Court decides in the Fokus Bank Case | ||
| Hot links | ||
| 2004-10 | ||
| Various proposals of law | ||
| Calculating exempt gains under participation exemption | ||
| Paying exempt gain to third party not deductible | ||
| Loan not requalified as informal share capital | ||
| Q&A Decree on transfer of losses upon deconsolidation | ||
| New general decree for treaty dividend/interest reductions/refunds | ||
| Call and put options can not transfer beneficial ownership | ||
| Other points of interest | ||
| - Deemed interest deductible | ||
| - Management and financial services split for VAT | ||
| - Gibraltar Co's qualify for Parent/Subsidiary Directive | ||
| - KLM Protocol to Dutch/French tax treaty | ||
| - Interest deduction limitation under art.10a'2 | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Proposed laws on exchange of information | ||
| Proposed law to implement Hughes de Lasteyrie du Sailliant | ||
| Dutch High Court rules on freedom to provide services | ||
| Hot links | ||
| 2004-09 | ||
| Various Dutch Decrees on advance certainty reissued | ||
| Amendments to the tax regime of the Netherlands Antilles | ||
| Dutch dividend tax on acquired foreign profit reserves | ||
| Other points of interest | ||
| - 12 year statute of limitations | ||
| - Slovanian & Albanian treaties | ||
| EU RELATED TAX DEVELOPMENTS | ||
| High Court of Den Bosch applies the De Groot decision | ||
| ECJ Decides in the Petri Manninen Case | ||
| 2004-08 | ||
| Decree on tax consolidation of foreign tax relief | ||
| Extra difficult burden of proof financial institutions | ||
| Proposed law on debt conversion and writing down participations | ||
| Other points of interest | ||
| - VAT on sale of shares | ||
| - Belgian & Latvian treaties | ||
| - Written down loan not recharacterised as equity | ||
| EU RELATED TAX DEVELOPMENTS | ||
| ECJ cases: Anneliese Lenz & Jean-Claude Weidert/Élisabeth Paulus | ||
| ECJ Order: Jean-Claude de Baeck | ||
| UK CFC System on trial | ||
| Hot links | ||
| 2004-07 | ||
| Fiscal Maintenance Act 2004 | ||
| Decree on repurchased shares for employee stock options | ||
| Treaty position of Dutch pension funds | ||
| Converting debt to equity and deducting acquisition costs participations | ||
| Other points of interest | ||
| - Residence NA NV | ||
| - Tax sparing credits Dutch/Israel treaty | ||
| - Meaning of "interest paid" in tax treaties | ||
| - US/Dutch tax treaty protocol | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Application extended list of entities under Parent/Subsidiary Directive | ||
| Fiscal Maintenance Act 2004: Interest and Royalty Directive | ||
| Hot links | ||
| 2004-06 | ||
| High Court rules on interest to Belgian Coordination Center | ||
| Non-deductible acquisition costs for participations | ||
| Indonesian court declares Dutch conduit bonds null and void | ||
| Q&A Decree on Dutch roll over provisions | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Cross border tax consolidation | ||
| Dutch Supreme Court denies share merger facility | ||
| Hot link | ||
| 2004-05 | ||
| High Court rules on LLC’s and participation exemption | ||
| Q&A Decree on limitation of interest deductions | ||
| Dutch dividend tax due in spite of prior emigration BV | ||
| High Court on participation exemption and prêt participatif | ||
| Deferring liquidation may not prevent losing tax losses | ||
| Other points of interest | ||
| - Guide on double taxation | ||
| - Exemption dividend tax in consolidated groups | ||
| - Dutch Federation calls for EU proof legislation | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Merger directive applies to merging investment companies | ||
| Dutch Supreme Court implement ECJ’s De Groot decision | ||
| Hot links | ||
| 2004-04 | ||
| State Secretary reports on Special Knowledge Groups | ||
| Dividend tax on acquisition of foreign undistributed profits | ||
| Is it possible to allocate shares to a Dutch p.e.? | ||
| Overview of Dutch tax treaty negotiations | ||
| Other points of interest | ||
| - Need to request capital duty exemption, EU compliant? | ||
| - 12 year statute of limitations | ||
| - US-Dutch Tax Treaty Protocol | ||
| EU RELATED TAX DEVELOPMENTS | ||
| ECJ & Dutch High Court rules: exit taxes not EU compliant | ||
| Proposed changes to Interest & Royalty Directive | ||
| Hot links | ||
| 2004-03 | ||
| State Secretary announces overhaul of Dutch Corporate Tax | ||
| Q&A on Dutch participation exemption after Bosal | ||
| US-Dutch protocol to income tax treaty signed | ||
| Ministry publishes APA/ATR statistics | ||
| Capital Duty relief for contribution of holding companies | ||
| Anti-abuse laws permanent establishment losses announced | ||
| Other points of interest | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Commission consultations on corporate migrations | ||
| Member of parliament questions EU compatibility of Dutch-Belgian tax treaty | ||
| 2004-02 | ||
| Allocation of swap to finance branch and treatment of full hedge | ||
| Valuation of bonds and determination of existence of a p.e. | ||
| Anti-abuse laws re. participation exemption announced | ||
| Other points of interest | ||
| - NA Reinsurer not resident in the Netherlans | ||
| - Liquidation shortly after emigration | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Recommended questions to ECJ on Merger Directive | ||
| Honouring Saint Gobain: Treaty benefits for Dutch p.e.'s | ||
| Politics as usual? Commission vs Council on State Aid | ||
| Hot links | ||
| 2004-01 | ||
| Proposed law on distressed debt & participation exemption | ||
| GmbH realises tax free gain on Dutch real estate | ||
| Qualification of redemption of shares under tax treaties | ||
| Valuation of waiving guarantees granted by a subsidiary | ||
| Other points of interest | ||
| - Proposed laws adopted | ||
| EU RELATED TAX DEVELOPMENTS | ||
| Participation exemption re liquidation losses contra EU law | ||
| Discrimination against foreign pension funds | ||
| Dutch inheritance law contravenes free capital movement | ||
| 2003-12 | ||
| NA NV not resident in the Netherlands | ||
| BV continues right to carry forward profits | ||
| Q&A Decree on Surtax | ||
| Tonnage regime for Dutch tugs qualified as illegal state aid | ||
| Two decisions regarding Dutch capital duty | ||
| Other points of interest | ||
| - Proposed laws adopted | ||
| - Supreme Court rules on hyperinflationary branch profits | ||
| - ECJ decisions in Zita Modes SA, Diana Lindman & Fleck-Shilling | ||
| 2003-11 | ||
| Bosal: Proposed legislation | ||
| Q&A Decree on new tax consolidated group regime | ||
| Proposed extension of EC Merger Directive | ||
| Other points of interest | ||
| - Decree on div.tax, share premium and share mergers | ||
| - Enhanced Mutual Agreement Procedure under US/Dutch treaty | ||
| 2003-10 | ||
| Bosal: Dutch participation exemption contravenes EU law | ||
| Supreme Court rules on treaties and deemed income | ||
| ECJ shoots down Dutch Law on Foreign Companies | ||
| Q&A Decree on loss carry forward | ||
| Other points of interest | ||
| Annex: Tax package 2004 | ||
| - ECJ decision in Oce vd Grinten | ||
| - No double spread on layer conduit finance companies | ||
| - Watchdog for Dutch accountants | ||
| - Does Chinese merchant in Canada have Dutch p.e. | ||
| - EU Commission proposes more coordination in combatting fraud | ||
| - Decree on VAT and factoring | ||
| 2003-09 | ||
| Q&A Decree published on participation exemption | ||
| Proposal to extend reach EC Parent/Subsidiary Directive | ||
| Allocation of swap to finance branch and treatment of (full) hedges | ||
| Material test of investment stimulus for tax sparing credit | ||
| State Secretary temporarily refuses Supreme Court VAT decision | ||
| Other points of interest | ||
| - Advocate General: Dutch base erosion rules not EU compliant | ||
| - Report on functioning of special knowledge groups | ||
| 2003-08 | ||
| Proposed legislation announced | ||
| Issuing preference shares in asset mergers | ||
| Q&A Decree on capital duty and hybrid loans | ||
| Moving hidden reserves back and thro within a tax consolidated group does not lead to tax upon deconsolidation | ||
| Other points of interest | ||
| - Is denial compensation all litigation fees EU compliant? | ||
| - Limited refunds of foreign tax by mutual investment funds not EU compliant | ||
| - Polish/Dutch treaty entered into force | ||
| 2003-07 | ||
| Consultations between Ministry and tax consultants on Special Knowledge Groups | ||
| Adoption of tax package | ||
| Update on relief from tax overkill distressed debtors | ||
| Further limitations on the deduction of bribes | ||
| Other points of interest | ||
| - Advocate General: VAT refunds on sale of subsidiary | ||
| - ECJ: KapHag renditefonds | ||
| - ECJ: Kraftfahrzeuge Factory | ||
| - Ending Dutch Film CV's (limited partnerships) | ||
| 2003-06 | ||
| New Dutch Minister and State Secretary of Finance | ||
| Proposed VAT legislation on E-commerce | ||
| Meaning of interest 'paid' in tax treaties | ||
| Prevention of double taxation on hyper inflationary profits | ||
| Burden of proof leads to loss of interest deduction | ||
| Other points of interest | ||
| - Q&A decree on Dutch mutual investment funds | ||
| - Parliamentary questions on negotiations US/Dutch tax treaty | ||
| 2003-05 | ||
| Clarification “Subject to tax” criterium participation exemption | ||
| No mercy for FX gain on 2 day acquisition deposit | ||
| Extension of grandfathering participation exemption earn out arrangements and adjusted sales prices | ||
| Q & A Decree on functional currency regime | ||
| Other points of interest | ||
| - Report on making APA practice more effective | ||
| - Announcement reorganisation Special Knowledge Groups | ||
| - Draft legislation on supervision Dutch Trust Companies | ||
| 2003-04 | ||
| Deduction of deemed interest costs allowed | ||
| EU rules and exit taxes | ||
| Limitations on the deduction of interest | ||
| Other points of interest | ||
| - Q&A Decree on roll over relief | ||
| - Costs for dismissing board of subsidiary not deductible | ||
| - Supreme Court: VAT on sale of subsidiary refundable | ||
| 2003-03 | ||
| State Aid investigation into Dutch Group Finance Company Regime finalised | ||
| Limited relief on interest deduction Exchangeables | ||
| Q & A decree on Tax Consolidated Group Regime | ||
| Other points of interest | ||
| - Dutch pe of SwissCo can form consolidation | ||
| - Double taxation under art. 10a CIT | ||
| - Insurance co's get no roll over relief on sale of shares | ||
| 2003-02 | ||
| Political agreement on Tax Package | ||
| VAT on conduit loans | ||
| Deemed residence rules inheritance tax contravene community law | ||
| Realisation of profits in sight of emigration | ||
| 2003-01 | ||
| Decree Tax Consolidated Group 2003 | ||
| State Secretary denies worsening of Dutch investment climate/promises relief distressed debtors | ||
| Guidance on Capital Duty published | ||
| Supreme Court rules on allocation of shares to Dutch PE | ||
| - Proposed legislation adopted | ||
| - Draft legislation announced on deduction acquisistion cost participation | ||
| - No more requests Dutch group finance company regime | ||
| - Supreme Court: Tax follows accounting on redemption of shares | ||
| 2002-12 | ||
| Proposed legislation 2003 | ||
| Supreme Court: Options and Participation exemption | ||
| Parliament questions Knowledge groups/Code of Conduct | ||
| Dividendstripping rules in case of reorgs | ||
| - Dutch legislative process criticised | ||
| - No dynamic interpretation Dutch/Swiss tax treaty | ||
| Home | ||