Sign New Mexico Trademark Assignment Agreement Secure

Document type sign trademark assignment agreement new mexico secure

dear ladies and gentlemen welcome to Priscilla and our customers request this conference will be recorded during the presentation you have no opportunity chose questions by the tan box in your webcast window your questions will then be on sit at the end of the conference we are now hand you over to I'm Priscilla who will start today's presentation thank you so a good afternoon everybody and welcome to our Deloitte transfer pricing web cast with a focus today on Mexico and Central America so my name is address polite I'm a transfer pricing director in our Deloitte German office and I'm also responsible for the Latin American competence center within our German transfer pricing practice with you today is also Eduardo Campos Martinez he is a transfer pricing partner in our Deloitte Mexico office and he will be sharing with us today the specific developments in transfer pricing in a post beps environment in this region this will be the first of two series of webcasts where today we will be specifically focusing on Mexico and Central America with a special attention on controversy and planning topics including a recent developments in the transfer pricing legislation in the region as you know the region has gone through significant changes in its regulatory landscape and approaches to tax audits in relation to transfer pricing it is of crucial importance therefore that multinational companies understand these regulatory changes which we estimate will bring a higher level of scrutiny in the region and will force certain companies to think of a regional strategy on how to manage their transfer pricing risks and opportunities in these countries so without further ado I will hand it over now to Eduardo who will guide us through today's presentation as mentioned earlier if you have any questions during the session feel free to send us your queries and we will answer these in the Q&A slot that we have set aside for the end of session so without further ado Eduardo please go ahead thanks Andres good afternoon for everyone thank you for joining this webcast as hundred mentioned the idea is to cover certain topics regarding Mexico transfer pricing legislation as well as all Central America countries we have a lot of information to cover the idea is to go through all sides probably some of them it's information that it's going to be also then available for you and so you can have an idea of certain topics we would like to try to focus on on certain matters regarding PPR its controversy APA not only next but also Central America so first and probably as you might be aware in Mexico we had elections a few months ago a couple of months ago and we have an important change in our network government this is the first time that a the body from the left side is going to to be running the country and probably I mean that's a political thing but but what we wanted to address is that even though we're going to have a change in the body that is much too one day the government was the elected president has mentioned in this in different different news and in the in different event he's saying that he's not going to change the way that the tax authorities have been running with a lot of different topics one of them is for pricing so we believed that he is going to continue any fiscal measures from the past and that because they need to to obtain a lot of or they believe they can obtain a lot of money from the taxpayers because so so he's going to continue with all the best matters as and that's how we think that's going to go through so Mexico and I have been part of the whole city as well as a g20 for a long time it's the country that leads all the Latin America region so basically we have a lot of different rules that once they have been published in Mexico then the other Central or Latin America countries normally goes with the same view or the same rules that that Mexico implementing in its own country so we have a lot of recent regulatory changes we have new chapters that have been disclosed in the OCD guidelines and and those changes has already been included part of them in our Mexican income tax law for example regarding functional analysis we have more detailed explanation on how to to do it how to how to detail explanation of the functional analysis there's have being a lot of of activity between the Mexican government and the IRS in the u.s. mainly those frameworks has been in order to avoid double taxation but at the same time and that's something that probably we will further discuss also be able to have more bilateral ABA as well as math procedures so they're having a lot of work between the two governments in order to set up more amaura communication and work between both countries we also have new rules on that that's pretty important that's something that that all of you should be aware we have new rules regarding for suppressing adjustments in the past I mean only if you comply with an arm's-length value even though you move it between an interpreter range and if you have certain profit margin and you go from the lower to the upper quartile or or the opposite then there was no problem and you would only say that since you are complying with chippie rules you don't have to do anything else now we have new new rules for transfer pricing adjustments I'm going to explain them a little bit later also the new transfer pricing documentation standards it is pretty much aligned with a good new functional analysis on how to analyze certain type of transactions and and also once again the debt judgement for transfer pricing adjustment rules for we have one change in 2016 but they make the most important one seems this kind of legislation was in 1998 in Mexico this is the first CPI judgment for 18 that it's going to be pretty extensive and you have to comply with a lot of rules if this is live I mean this is something probably pretty easy but what I wanted to address with this is that willful or City rules in Mexico we have a the six different acceptable methods but something that is important and you should all keep in mind is that we apply the best method rule so if you are analyzing its transaction between related parties it's very important that first you you review that you don't have any kind of cop internal cop or a turtle cup that you can apply in your in your analysis and then move forward and explain why you are not using the other methods we have seen in in a lot of TP works perform in Mexico that the business best method rule is not applies and that and that can create a lot of issues so I've seen it in a lot of tax audits and and even though this might be a simple thing to talk about it's something that you need to comply or that create a lot of controversy in impact audit and finally in this is life something that is also very important it's a simple thing once again but I've seen in a lot of cases is that we need to use a comparable company information for public companies we're not allowed to use the information of private companies that's something that I've seen in certain cases with your European work because I mean that's something that is possible in certain places in Europe you can use it as a benchmark in the case of Mexico and actually that's the same thing for all Latin America countries you must use information from public companies I mainly focus on us databases but we are able to use other databases for all worldwide companies but once again what I've seen in tax audit is that if you are using for example a comparable company from Japan if at least you are not able to show all the chain K or the annual report from the company in English and and and for example you presented it in Japanese that information they are not they are not accepting it so please keep in mind this this point finally from from the Mexican side we have a substrate type report that probably most of you might be a word we call it dictum and fiscal that's something that you need to filed every year and now companies with certain amount of revenues or certain amount of assets or number of employees needs to present this kind of information this is the authorities report but there is another option that option is called disease and that is it's pretty much the same information there are certain appendix that were eliminated but from a trusted pricing perspective and that's the main point of this is that the coming fiscal or this if both of them requires a lot of information regarding four sessions with related parties and this information goes from the related party tax ID the amount of the transaction the type of method that that you are using and how you confirm that that transaction complies with an arm's length value and now the main difference between the big stamp Memphis Calif or sub story that will force against that it is is it is the deadline that's the red line from for the disease and that's when the taxpayer presents its own information not based on an external auditors then you need to file the disease on the last day of March and why is that important because if if that's the way that taxpayer is going to go through then you have to that you need to fulfill or to comply or finish the EP studies before that time so I mean that's something that the role taxpayer should be a world that you need to be very careful because it's representing this kind of disease then deadline is going to be March day one and if you are presenting the victim NP scholarship rare then you are you need to comply or file this substrate back report by the end of July sometimes we have certain differences they could change but but let's say between the first of July of till the end of the month now you are going to move forward with with certain hot topics in all Central America countries what I would say is that and I and I think this is a very good and positive point for the region a lot of countries even though they always mention that we let a public transaction suit should be a referred market value or that they could question certain transactions the word not really the rules in place and that's something that now at nowadays almost all countries already have so let's go and move to for example Costa Rica Costa Rica probably is one of the countries with us with it with pressure pricing rules since 2016 they started they started having specific rules they have also introduced in fiscal year 2017 a new rule regarding master file so so if you have certainly specific amount of revenues and transactions with foreign related bodies then for 2017 in 2018 you must comply and present master file and at the same time since they are focusing in these master files but right now they suspended this part surprising informative return they are right now seeing how they want to create a new tax return for foreign surprising so right now they suspended it but we believe they are going pretty quick to have a new format and and to present new rules but but please be aware of these new rules regarding master file now it is something that that is pretty unique but but in Costa Rica they have all very turn implementation of other international tax matters and that has created a new resolution for for international matters including transactions with with related parties and what they they want to have it more contact with without OCD members so these were solution but mainly is focusing is it to determine and execute best practices and negotiations with a with a with transfer pricing and international tax matters withholding tax and transactions with related parties also they are trying to to coordinate and have recommendations for for all these best matters from the OCD in their legislation so that's why for 2017 they are requesting the Master File in the case of El Salvador now for 2018 they have they have obligations for transfer pricing rules they are the case of El Salvador they are really doing things pretty similar to to our Mexican transfer pricing rules actually there was a lot of communication between the two governments between tax authorities so so everything is pretty aligned to what we have in Mexico and I just mentioned for example bed method rule comparable company it's pretty much the same in the case of Guatemala they have a 2016 they publish that plan surprising potential guide they want to cover all the all the information only for foreign related parties and that's something probably that I didn't mention when I was talking about Mexico in Mexico we have to have a transfer pricing documentation for pouring related bodies but also for domestic related parties observe the transaction between two entities in Mexico still you have have a teepee working place in the case of all Central American countries they are not right now only focusing on foreign related parties and in the case of Guatemala in 2017 they they mentioned in their in their income tax well that there should be an informative return regarding transfer pricing it's not only a related party return but it's also make with certain income tax return regarding other topics but you have to include certain things and and that's why you must have a city studying place no later than March 31 of the next year because since it is part of the income tax return you have to have the report in that in that time now in the case of older such as administration start to having new rules for transfer pricing since 2016 there has not been significant changes and everything is placed or based for no CV guidelines in the case of Nicaragua it's pretty much the same as El Salvador Honduras they have new rules since 2017 and as I mentioned everyone is considering their TP rules based on our city guidelines and in the case of Nicaragua probably the best topic to be aware of is that local and master file should be presented to the tax authorities with a very small or limited scope you don't have to you have a lot of detailed information and actually this this kind of rule applies only for a few sax players in the country and finally in the case of Panama they already have also key Peru and that's something that probably I'm going to later explain but even though there are special pricing rules for Panama there I believe there are a lot of good options to to create or to plan and to have you need transactions with related parties based on Panama there are a lot of things that could be helpful from a tax planning side we'll probably just just to give you an idea there are a lot of things to cover from a reporting side from a documentation one of you they are requesting on transactional basis that opens the roll related party transaction complies with ransom values you need to have a functional analysis so Costa Rica a Panama probably from Central America they are the two countries with a with more detailed information regarding for enterprises now let's move to the next topic which I believe is it's pretty important because we have a lot of activities mainly in Mexico but I'm also aware of a couple of audits in other countries there are a lot of things that that that you should be aware of here we can see a mole of charts with all the different matters that that taxpayers are under examination considering in Mexico for example something that is pretty important is that you must have are all the information from your related party and even though I mean it's probably something it's a formality if you don't have all a question backs IDs from your related party then you can start having a lot of issues in Mexico so so please be aware of it if you are having transactions with with tax heaven for example it's pretty easy for sacrifices almost in all Central America Mexico countries I mean that's that part is going to be non-deductible you need to comply with a lot of rules it's very difficult to comply with all of them so transactions with tax havens be aware of them be careful with how you structure them and only and that we let it to my previous comment that's not part of Panama if you are doing any transactions with a tax haven then you don't have this issue in Panama and so for example if you're having services rendered from a from a specific point Panama's would be a good option they are not reviewing it from a famas from the tax authority side and somethin that it's pretty important and please keep it in mind in the case of Mexico and and over the last year I've been ascending probably four or five different transfer pricing audits for tax payers and something that is pretty common when I met the head of of all the sh t we call it that in Mexico with the tax administration Chikara an echo file with the tax revenue and the net revenue of the taxpayer over the last year between five to ten years so if this they if they start seeing that a company has to loss for several years and then they move forward and they review that that you have a lot of transactions with foreign related parties mainly because they can review it in the statutory exact report or in the transfer pricing for massive returns and they match that you have a lot of transactions with related parties and also at the same time you have losses for several years it's going to be you will be probably in a risk of having a transfer pricing audit so to have in mind that other things is for example restructuring if you have restructured your business now in Mexico tax authorities are focusing in in exit path that that's something we didn't see in previous years nowadays they are start saying that exit that if you're selling your business somewhere else that's something that now they are focusing is that that they have the skills from the back Authority side to review it actually from the transfer pricing the parks department from from the tax authority side they have a lot of people working for them that previously used to work for four big four firms so they have employees with a lot of expertise regarding transfer pricing so now there's that after rallies are not only in a formal matter but they are also doing previews considering more substance things and economic things so so if you are doing any kind of refresher please be careful having older your support what our topics will lack of databases and that's something that in certain countries they are really focusing in as I mentioned before normally all all in the region all tax administration's they always want to see public databases not private ones so so information should be for everyone and that authorities could reveal in in websites in any kind of public information not not really databases porches from from any vendor so be aware of that and finally intangibles that's something a pretty common right now tax authorities are saying that even though the VIP intellectual property could be old and by order it countries by pet water what they are saying is that also you are creating certain kind of intangibles in your subsidiary mainly considering this because you are creating new markets because probably you are the polyp you are selling they are using them in order to comply with certain specifications from consent from certain countries so what they are saying is that you are taxpayers you should not only focus on certain profitability of the superior based on for example the low cost distributor but also if you are doing something else in order to have that IP or that intangible keep on growing then you should also have higher profit margin for for that subsidiary this is only half as administrations have certain specific facts base according to bethe something general but I mean I included this part only if you want to reduce later on in case of Mexican probably going in something more specific touching sections as you can see in this graphic has increased more than eight times as I mentioned before they have more skill to review companies and and something that is important this it's not only that a transfer pricing audit kit come up from the TG department but there are other at a department from the tax authority side that for example international fat area that if they start seeing a matter of withholding that from an interest transaction if they see that it is for example along with a related party in previous years they would only focus on the withholding matter now they have a lot of internal communication so they would say oh look CP Department there's a long between rare parties I don't feel comfortable with the interest rate why don't you also open and not it so they have a lot of communication with other be achieved apartment with without with a custom performance so they are now having more communication and at the same time they are doing their audits with with with more substance will substance between formal things as I mentioned before what what they will always try to review is if you are transferring ordering tangible asset if you have professions with a with low taxation jurisdictions that would probably like to open another then what kind of of transactions or risk assessment models tax authorities are considering in order to open an audit well if you're having royalty payments or any kind of intangible payments abroad Mexico that's something that they that that would create a probably some kind of suspicious from their life I'm not saying that it doesn't comply with runs and value but but they are really focusing if you're having that kind of transactions corporate services that's a main topic not only I mean I know that there are a lot of companies that that that need to charge to set their headquarter services that is they don't do it they will have an eg P issue in that in the headquarters country or Europe us but at the same time you should be aware that not only you don't need only to comply with our answer and valuing the transaction not just saying if you are having a cost was ten percent is a ten percent it's correct or not now taxation or is it or the tax audit they are focusing on all the support documentation to prove that the service was worried vendor that there is a real benefit for the subsidiaries but that you are not charging is in a cost allocation basis and if you are doing so it's possible also in Mexico now to to deduct expenses coming from coastal location transactions but you need to comply with a lot of other rules besides transfer pricing so so they're tax authorities are focusing and this kind of mother financial financial transactions forward transactions that's something that they want to relieve probably the in Guatemala they start having a now they purchase for example uh databases so that in previous years they did they didn't even have a lot of a to confirm comparable companies information now they have it and they would like in the future to have more CP audits right now they are not really so active in Guatemala regarding from surprising and normally when they're scenarios is regarding other kind of tax matters and then they would have a small portion of related party in Panama they have a little bit more emphasized in certain key drivers for transactions with relate bodies but but once again tax authorities are not really deeply diving into audits for forty P matters but but that's probably something that with over the years they would start doing but right now they are not so active and considering the time probably I'd like to move forward and discuss other two topics we still have ten Marvin and then of course we're open to questions regarding APA and math are something that is I mean there are certain APA s going on in Mexico Nicola wondrous and what am i laughs mainly APA in Mexico for previous years were focused on maquiladora and concert manufacturers when nowadays this have been starting to change and the ad libel is that's a very good point I was involved in a review for a big APA in Mexico it was for the automotive industry and the company actually it's from Germany it was a big APA it was not right now it's not bilateral but but they do live probably in the future they would like to to do something else but but this APA was was a big big matter for the sacrifices they they were very interested in trying to finish this one you know in enough so long time so it's pretty much closed everything seems to be fine and these took over more or less two years to finish it and now what we have seen as a firm is that APA is in Mexico are not going to be only for maquiladoras so now we are moving to a new area so if you are having some rich transaction or not rescue but if you are having a new operation in Mexico that you don't have to run any risk and to be completely sure about your profitability because it's not your business models will not accent APA is now is nowadays it's a good option instead it's a long procedure but but as I was mentioning now the APA Department has a lot of skills they have been working a lot with us with us with the consultants with the firms besides the taxpayer to to really try to finish and close the procedures more procedures will with less time expected time to close them and bilateral APA that's a tough one but but still we have nowadays certain cases with the u.s. there are no I believe right now there are certain eight bilateral IPAs in place or means in the process of trying to finish them with Japan and on I believe also couple of them with Europe so I believe we will see in the future more of more bilateral IPAs in Mexico and also math since there are so a lot of tax controversy going on in Mexico maths it's always an alternative and and there has been a couple of successful one at least in our firm regarding math so it's also it's also possible that doesn't main thing that I wanted to express here in this graphic you can see how APA or bilateral base and what maps certainly statistics regarding the different industries services automotive industry manufacturing industries probably those are the three more important ones also there's a part for pharmaceutical but but right now are these three different industries or economics first I wonder or bilateral or unilateral RFPs are are focusing now other transfer pricing development and that the last topic I wanted to talk about today this is a new rule it's pretty new it was published on the 11th of your life and and it's effective in the following day so now if you were doing a transaction with related parties with a related party search in a foreign country and and then you realize that for example if it's a distributor you are living a lot of profit margin in the in depth Mexicans of theory and then you say okay I'm going to increase or at your surprise in order to have an optimum value and also at the same time do not have an issue in my headquarters then you need to comply with a lot of rules we have them in the presentation we will live probably they might publish in the following month something a little bit more clear because from our side we live till there are a lot of things to work on because it's it's complicated to to follow it but but the main thing is that if you are doing any kind of adjustment that we let a body then in that movement you need to file a document with certain specifications to the past authorities such that that document sorry that document is going to be signed by your transfer pricing consultant with certain specification of co-signing it the partners should have this certain experience and other things and then all that information you need to file it to the tax authorities explain them why you are doing that kind of adjustment so they in real time they will have all the information to confirm whether they feel comfortable or not with this type of a judgment that you are doing and what we believe is going to happen is that if they feel something that they are not completely sure about about it they will open immediately as transfer pricing on it here are certain requirements or specific things that taxpayers should be aware of you need to have timely file for example your annual cash return your BC for the substrate that report the local master file that consumers want to report all that things if you don't present on time or you didn't file all these matters or all these patterns then you are you won't be able to add just a transaction with Tulare parties and do it deductible so keep it in mind at the same time as I was mentioning you should also have a teepee study in place for the adjustment is not that you that that one's the fiscal year is finished that you have your teepee documentation for the whole year now in this case if you are doing an adjustment let's say in in October then you will joomla's have a teepee announcer or opinion from from a third party or internal lipids for a teepee opinion say that that becomes that the transaction compliance their values and that even though you are doing that you government still just you have a fair market value but that document needs to be signed by the edge by the experts and at the same time that you are doing that you will have to presented it with with other specifics online then you would also need to have an invoice for the adjustment in that moment if you are just doing the adjustment without an invoice then that far is going to be non deductible and of course other matters has value-added tax and gifts need to be need to be done since we're having just a few moments to finish up some relevant aspects I would say regarding services please as I mentioned before you need to comply with all CP regulations but also going a little bit forward you need to have a lot of support documentation and we're not just saying about we're not talking about only agreements or invoices we are talking about emails communications or memorandums any document that might support the service that was really render and in order to demonstrate that there's a real benefit for the subsidiaries as I mentioned before it cost allocations nowadays Mexico are could be considered as adaptable but they need to comply with a specific rule and of course a namsan value in tangibles are that's something that we briefly discussed previously tax authorities nowadays are saying that that's all the dent analysis and how they activities to keep that keeps the intangible to have a value it's not only the headquarters do but all so something that subsidiaries in the case of Mexico Mexico series are also helping to develop and that has a lot that has value and that value should be incorporated in the profitability of the Mexican self-interest back to back be a world of a business restructures if you are a full fledge and you're converting it to compromise backward which we will be very careful with that kind of of things it's it's vegetable now for tax authorities with all the information that that you need to to file and they will always like to see if there's an exit tax or not and for my side I believed that everything I wanted to cover in this webcast but so probably we can move forward in the following minutes is to talk about any questions you might have yes thank you Eduardo for the detailed and informative presentation we do have a lot of questions to ask and one one that is regularly coming up and this is a little bit in the topic that you just touched upon on the services and this is also in my experience a big topic for many German multinationals when they are charging their services to their Latin American subsidiaries so what is the right amount of backup information that you should include in your documentation so obviously you have you will describe the services you will describe the benefit test and you will include the markup etc but what what is really the right amount of information you want to include in your documentation you mentioned that it is important to include meeting notes and emails and so forth but when when you're talking about millions of worth of services that are being charged let's say to a Mexican subsidiary you certainly cannot take the time to include everything so what is really the right amount of information that you want to include in the documentation as a first line of defense yeah I mean it's always difficult and Reza I'm sorry for the thing that I'm going to say about this it's not never is enough for them but but as but at the end for example if we are saying as a third party we are rendering a transfer pricing service but well then you would file the proposal you will have a tipi document that is the final document and you will have working papers and the profits is a very easy example but in the case of services but they want to see and that's how I've een able to support it in in CPR it is communications emails it's very important but also the deliverables for example if we are talking about engineering services for the design of our products that it's going to manage to be manufacture in Mexico and all that activities are performed in the headquarter probably you might have a scrolling or or you will have a memorandum explaining all the specifications from how to manufacture this product so that isn't these are examples it depends on each case but at the end there should be deliverables beside the agreement all examples on this what if you are talking about reviewing financial statements or reviewing an agreement from the legal side I think the best go the best way going through is at least have a memorandum saying all the everything that you agree on the meeting or in the phone call on how to to prepare an agreement for example so all those coming that probably you would only say it off over the phone you need to are my recommendation would be to include them in a paper so it's not easy it's not something that that there's rules specifically saying what what you need depends on each case but at the end is also support for the deliverable of any kind of service and I'm sorry like that I cannot be more specific but but it depends on each case yes okay thank you I definitely understand that I think you're the message is really when we are documenting the services for a Mexican subsidiary I think we have to go a little bit beyond just your typical benefit benefit test and description of the services but to really include some information there that will show the tax authorities that there is a tangible benefit so to speak with regard to the raziel here thank you for that so at the next question that's coming up is with regards to permit establishment and it seems to be a bit general question but maybe if you want to focus on Mexico and in perhaps any knowledge you might have on Central America on this but how risk how common or permanent establishments in case of tax audit so what how aggressive our tax authorities when it comes to a firmly establishment they have not really focused on permanent stablishment however it's important to keep in mind is if you are having a PE in Mexico only Mexico that's not the case for Central America but if you're having a P in Mexico still there needs to to have a key pease documentation in place and even though it is the same company you say how you it is a failure in our in our rule and you need to have an arm's length value for the portion that you are having as a fee is in Mexico so they are not really auditing then auditing then but but but still we have rules would be okay thank you and another question that is coming with regards to tax audit settlements so how often the tax payers try to settle teepee adjustments in court Versalles entering into a mutual agreement procedure and how effective our court disputes in Mexico normally and respects authorities are very aggressive on how they are a company normally you will have you normally what old case I've seen or I have heard they always try to sell the hook before going to trial so probably I would say that 80 or 90 percent of all cases it's better to sell now we have a a new well it's not so new but from a couple of years ago we have a a new government agency that is called flow record there it helps taxpayers so if you have an audit with the tax authorities and you can go through this agency in order to sell with the tax authorities and over probably in the last two years I've seen a lot of of cases being resolved for this agency for lacan so it is pretty common to sell instead of going to trial and something that is that it's killed something that as a country we need to move forward but if you go to trial probably the judge won't be a real expert in front of Breton matter so they would realize someone else so going to trial could be you could go for a lot of years you will have to guarantee the amount of attack assessment and then mean it's not only that they will start looking at technical things for technical matters but also they would sadly looking at a lot of legal matters so it's always better to settle into a first segment to do it instead of going to trial and that's how or almost all cases have been resolved in the last year's okay thank you I think we have several questions left but but I would like to perhaps end with this question as I think it's also one of the most important topics that tackles most of the Mexican companies and Central America perhaps as well and this was a to do with what you mentioned about your the new regulation regarding a tipi adjustments and also the fact that the Mexican authorities see that extensive marketing activities should be remunerated excessive local market activity should be remunerated the next question is basically asking how common are residual license is tackled in tax orders based on your experience well you know I mean it if this Forman if they start looking at an audit and they listen that you have decreases the profit margin of finances because you are doing any kind of a judgment considering that the other party or the other side of the transaction is not really earning a reasonable profit margin they would still say that that is only admirable of the Mexican company and there they could be very very rapid run and that's why we have these new rules for 2018 they want to be total control of any kind of adjustment that you which is are coming from from from a formulated party right right okay thank you very much so I think for the interest of time that was the last question we didn't have a lot of questions that we were not able to respond but we will be able to respond them directly to the participants that raise them in the meantime if you have any further questions on these topics feel free to reach out to us so thank you Eduardo also for for your information in detail presentation thank you everybody for for listening and attending our webcast please also make sure to stay tuned for our next latin-american webcast which will be focusing this time on south america including brazil so very interesting so thank you very much again everybody that is it for now thank you for your attention and until next time thank you