CC BY
19Направления совершенствования государственного регулирования вывоза капитала за рубеж
сч
СП £
Б
а
2 ©
Табакова Анастасия Сергеевна
аспирант кафедры мировой экономики, финансов и страхования, Академия труда и социальный отношений (АТиСО), tas_007@inbox.ru
Статья посвящена направлениям совершенствования государственного регулирования вывоза капитала за рубеж из России. В соответствии с целью работы, ее задачами стали проведение оценки существующей ситуации в области государственного регулирования вывоза капитала из России, определение эффективности использования существующих законодательных норм. Помимо того, проанализирован спектр направлений по совершенствованию государственной политики в сфере вывоза капитала за рубеж. Представлены новые направления по модернизации существующих мер государственного регулирования вывоза капитала, а также выявлены новые возможности успешного решения комплекса мер системы государственного регулирования вывоза капитала из России. Для успешного решения поставленных задач необходимо не только совершенство законодательной базы системы мер государственного регулирования вывоза капитала из России, но также активное использование преференции, получаемых при вхождении в международные торговые организации. Следует отметить, что все меры государственного регулирования вывоза капитала должны рассматриваться через призму национальных интересов страны для достижения более эффективного результата их использования. Обосновано, что наибольшая эффективность регулирующего воздействия системы инструментов реализации стратегии государственного регулирования вывоза капитала за рубеж проявляется при использовании совокупности экономических методов и форм в целесообразной последовательности.
Ключевые слова: инвестиционный договор, франчайзинг, налоговые инвестиции, налоговые кредиты, инвестиционная премия, таможенный тариф.
It should be recognized that the problem of export of capital abroad, both legal and illegal, will exist until a certain stability is established in the country, in the economy, until potential domestic investors believe in the reliability of the budget, tax, legal, institutional systems of the country. The failure of the state in the near future to take urgent legal, financial, economic measures to improve the Russian economy, to block the channels of illegal export of capital abroad in its various forms can lead to a further increase in the volume of export of capital from Russia, a new financial shock.
Permanent capital flight affects the Russian economy in the following way:
- The volume of foreign currency in the country is decreasing, the supply and the total money supply are decreasing. Rubles enter the foreign exchange market, are transferred to other monetary units, are exported or do not enter the country at all. Increasingly, there are cases of illegal withdrawal of assets and concealment of foreign currency earnings;
- Drop the amount of currency offered on MICEX. Consequences are narrowing of the «currency field», instability of the ruble. The volume of investment resources is reduced, there is a demand for loans from abroad;
- Accelerated political instability is increasing. Russian relations Federal oligarchs lose confidence in the course of the state, which should not be able to protect their assets. In the future, foreign currency trust falls and requires foreign Russian partners, the level of optimal capital outflow increases. It turns out a kind of important effect of «snowball»;
- Accelerated political instability is increasing. Russian relations Federal oligarchs lose confidence in the course of the state, which should not be able to protect their assets. In the future, foreign currency trust falls and requires foreign Russian partners, the level of optimal capital outflow increases. It turns out a kind of important effect of «snowball»;
- Again, it suffers from the economy of Russia. Slowing GDP growth, rising inflation and decrease in the volumes of the objectives of production;
- Social tensions are rising. The decrease in the quality of life leads to an increase in social tension in the country.
The sphere of legislative regulation of investment activities can be attributed to the well-known from the experience of a number of countries legalization of exported capital as a way to stimulate its import to Russia. At the expense of the population (according to the leading Western rating agencies more than $ 70 billion). The likely return of part of the capital for investment in Russia can be obtained investment in the amount of approximately, as estimated by the same group of economists,15-17 billion. The United States annually [27].
It is also required to develop standard investment agreements that would provide practical assistance to investors, reflecting the current international and domestic practice. medium-term Investment agreement is a complex civil transaction, which defines the object of investment, the volume and timing of investments, rights, obligations and responsibilities of the parties to the investment agreement. This agreement is an entrepreneurial contract, that is, a contract implemented at the expense and risk of the investor, which is a business plan, and it defines the costs and the period when the project will be paid back and will make a profit.
We are talking about the development of different types of standard investment contracts:
■ The contract of international leasing (financial lease) which has recently become widespread in Russia, in particular, in relation to aircraft;
• Concession agreement of the state with a foreign investor as a special type of contract, which is a combination of the conditions of the administrative contract and the civil contract and is an alternative to privatization.
■ Production sharing agreement between the state and a foreign investor, which is based on the Federal law of 30.12.95 № 225-FL «on production sharing agreements», but which contains only the main provisions, leaving them for details in a specific production sharing agreement;
■ Agreement on international production and marketing cooperation in the legal form of a joint venture agreement (simple partnership agreement), which does not create a legal
entity with foreign capital, but which is accompanied by cross-border transfer of equipment and technologies, and sometimes the creation of joint ownership in the field of production;
■ Franchising agreement (in the civil code of the Russian Federation called the commercial concession agreement), under which the right holder undertakes to provide the user for a fee for a period or without specifying the term of a set of exclusive rights owned by the right holder (the right to the brand name and (or) commercial designation; protected commercial information; trademark; service mark). The provisions of the civil code are not sufficient to regulate the franchise agreement (there are no provisions regulating the obligation to transfer the information necessary for the user by the right holder to the extent in detail, as is done in the model law on this issue of an international organization such as UNIDROIT).
It is necessary to return to the development of the draft Federal law «on state regulation of the export of Russian capital» («on Russian investments abroad»), attempts to change which were made to no avail in the state Duma in 2003. The concept of this draft law should be based on the need to minimize the illegal export of capital, reduce the placement of Russian capital in foreign countries for purely speculative or consumer purposes, while increasing direct Russian investment in the real sector of the economy, bringing income to Russian investors and the Russian state. It should provide for a full-fledged system of registration, accounting and control responsible for Russian investments abroad. According to various estimates, the value of Russian capital abroad, not counting the Federal property located abroad, ranges from 200 to 300 billion US dollars [28]. These are mainly foreign currency funds on accounts in foreign banks and commercial financial institutions, and real estate (city apartments, country villas). The law should provide for the traditional form of foreign trade facilitation in the form of direct investments, when Russian commercial organizations sell their own products abroad through subsidiaries and branches established by them outside the Russian Federation. Our analysis shows that firms with Russian capital established abroad that legally invest directly should have a positive impact on the Russian economy, which cannot be said about the numerous firms that illegally invest capital. Also to reflect in this law the need to reduce foreign portfolio investments, placement of funds in accounts
and deposits in foreign countries, the acquisition of real estate there.
It is necessary to formulate the principles of targeted state economic policy in its entirety, the key element of which should be a combination of economic and administrative levers to regulate the export of capital abroad. It is necessary to formulate provisions in the law on the system of accounting and reporting on foreign investments (capital exported abroad), state control over them, analysis of the effectiveness of investments made, Advisory and information support for Russian investors in Russia and its foreign missions, financial support for Russian direct investments by the state (participation in capital investments, provision of loans, insurance of direct investments).
In this regard, it is advisable to develop a Federal law «on state property of the Russian Federation abroad», since the decree of the Government of the Russian Federation No. 14 of January 5, 1995" on the management of Federal property located abroad « is already outdated. Conceptually, the new law should be linked to the goals of industrial policy growth, in particular, with the goals of protecting priority sectors of the Russian industry. Within the framework of the new law, it is necessary to restore the provision on annually updated programs of foreign trade activities with their approval simultaneously with the draft state budget, and in the development of this provision to adopt a new Federal law «on state support for exports», which, in our opinion, should create legal mechanisms for regulating and supporting exports in order to change its structure - the reorientation from raw materials to industrial high-tech exports with a high degree of import substitution in respect of finished products. The Federal law «on state support for exports» should provide for measures of direct and indirect subsidies for financing exports and import substitution and be accompanied by appropriate amendments and additions to the budget, tax, currency and customs legislation of the Russian Federation, as well as the legislation of the Russian Federation governing certain types of services and intellectual property rights. The provisions of this law should ensure the effective functioning of the system of state insurance and guarantee Russian exporters and Russian investments abroad against political and long-term commercial risks, support the participation of Russian organizations in the construction of industrial facilities abroad and expand the supply of complete equipment, including on the basis of intergovernmental
agreements with the provision of loans. Such a law should create the conditions for expanding markets for products of Russian high-tech industries, balancing optimal structure of Russian exports, maintain and expand international markets for Russian competitive products, at the same time the conditions for creation of preconditions for expansion of production with orientation to foreign markets and improve its structure. Simultaneously with the adoption of this law by the Government of the Russian Federation in the framework of Russia's accession to the WTO 22.08.2012, Russia intends to actively use article 27-29 of the WTO agreement on subsidies and countervailing measures to establish a transition period of up to 10 years for the course of restoring the competitiveness of the Russian manufacturing industry and the gradual adaptation of the course to the full and unconditional application of this Agreement. Without such a statement, all measures for state support of capital exports will be contrary to WTO rules, and Russia will permanently consolidate its position as «energy and raw materials appendage of developed countries».
An important aspect is the provision of tax advantages to commercial organizations that do not violate the law and contractual obligations, which will create conditions for the growth of their own investment resources. Tax advantages should be conditional and provide, first, incentives for the development of advanced technologies, the production of knowledge - intensive competitive products, training of highly qualified personnel, resource conservation and reduction of environmental pollution, and secondly, the growth of employment and increased wages of workers.
These tax benefits include:
- Tax and investment tax credits, which according to the Tax Code of the Russian Federation are not tax benefits, but rather regulatory and incentive instruments (it is advisable to increase the term of tax investment currency credits);
- Depreciation advantages, in particular, their accelerated accrual (it is required to change the order of depreciation so that the value of the new depreciable fixed assets is indexed by the value of the inflation index).
It is also necessary to pay special attention to the investment tax credit provided by Art. 66 - 67 of the Tax code of the Russian Federation, as one of the levers of state regulation of the volume of export of capital abroad. For its more effective use, it is necessary to provide for the procedure for its provision to commercial organizations
О
Ю i
*
to
2 a
8
сч
СП £
б
а
2 о
engaged in priority industries, and to adopt a decree of the Government of the Russian Federation «on the procedure for granting investment tax credit to commercial organizations engaged in priority industries». The resolution should determine the body responsible for making decisions on granting investment tax credits to enterprises of priority sectors. Priority sectors are determined by the relevant presidential decrees or government resolutions on the basis of the industrial development program. The purpose of the resolution is to increase the availability of investment tax credits to commercial organizations engaged in priority industries, to prevent abuse and to increase the efficiency of investment tax credits. The resolution is adopted in accordance with and pursuant to the Tax code of the Russian Federation and does not require amendments and additions to other regulatory legal acts.
Among other things, it is necessary to restore in the tax legislation the norm on the investment benefit, which is the right of exemption from taxation (or reduction of the tax burden) on income tax for commercial organizations that create new production based on the renewal of fixed assets at their own expense. The list of expenses deducted from the tax base and aimed at the development of production should be expanded to include the costs of training and advanced training, voluntary transfers to the loan Fund of industry and research and development financing funds, including the Russian Fund for technological development.
It is necessary to provide in the tax legislation the investment premium as a onetime measure for the commercial organizations occupied in priority industries in case of implementation by them large (over certain limits) expenses and expenses on technological updating of production in the form of exemption from the taxation of the certain amount of means over the made expenses under the agreement with tax authority. This measure applies to income tax.
In Russia, there is a need to develop a radically new Federal law» on currency regulation and currency control». To this end, it is necessary to make changes in the chamber of Commerce and industry of the Russian Federation and create under its auspices a special working group to develop a new Federal law «on currency regulation and currency control» or to make significant amendments to the government bill before its consideration in the second reading (by adopting some provisions of the said draft
group of deputies of the state Duma). The radically changed version of this law will require revision of numerous regulatory legal acts of the Central Bank of the Russian Federation.
When adopting legal acts in the field of customs regulation of the export of capital, it should be assumed that the customs business in Russia needs modernization. The Russian customs system does not fully meet the requirements. This is especially true of removing unjustified administrative obstacles, protecting Russian entrepreneurs from unfair competition, creating favorable conditions for foreign economic activity by, on the one hand, ensuring the safe cross-border movement of capital investment resources, and, on the other, simplifying customs procedures. We firmly believe that the radical restructuring of the customs administration system should ensure the comfortable implementation of the legal foreign economic activity of TNCs in the implementation of the export of capital from Russia abroad.
You must be guided by the fact that the main principles of the reform of customs administration are speeding up customs clearance, transparency and predictability of actions of customs authorities for the participants of foreign trade activities, the partnership approach in project relations, the issue of customs authorities with participants in foreign economic activities, including the establishment of effective procedures for the settlement of customs disputes.
Among the most important areas of the reform should be the improvement of the procedure of customs authorities, including the introduction of the principle of selectivity of customs control carried out in the course of customs clearance, the development and implementation of new mechanisms of cooperation between customs authorities and participants of foreign economic activity, by supporting the implemented system of electronic Declaration (ED - 2), the maintenance of a new system of complaints in the administrative order.
There is a need to revise the provision on the exclusion of export customs tariff regulated by certain legal acts of the Government of the Russian Federation, based on the task of reducing and ultimately abolishing export customs duties on investment resources in the form of products of high conversion of chemical, timber and metallurgical complexes, progressive reduction of export customs duties on oil and oil products by linking them with the level of tax on oil production. The
implementation of the tax burden transfer regime for domestic taxes and the optimization of the share of natural rent withdrawn by the state in the extraction of minerals will contribute to a gradual departure from the use of export duties and, thereby, due to the predictability of the overall tax burden, will contribute to the implementation of long-term investment programs of the fuel and energy complex of Russia.
In order to prevent monopolization and corruption in the provision of customs services, the exclusion of small and medium-sized businesses from customs activities, it is necessary, taking into account the opinion of a number of territorial chambers in the Russian Federation, to make a number of changes and additions to the new Customs code of the Russian Federation.
According to the government's Forecast of long - term socio - economic development of Russia until 2030, approved in March 2013, a sharp increase in the gross savings rate is necessary to improve the country's economy, primarily gross fixed capital formation - from 25 - 29% in 2018 to 25 - 32% in 2020 and 26-33% in 2030. This should be due to the strengthening of self-financing of enterprises and the growth of their Bank lending.
Reducing the flow of capital out of the country and shifting it to domestic investment could help to meet this challenge. This reduction requires a radical improvement in the investment climate in the Russian Federation, as a strategically important way to reduce the volume of capital exports from the country, up to the change in the nature of its economic model. At the same time, it is advisable to focus on another way - reducing the volume of capital exports by strengthening state regulation of this process, primarily by increasing its transparency. This is due to the possibility of obtaining the effect of this method in the medium term, without waiting for the improvement of the investment climate in the country.
Regulation of capital exports should be accompanied by measures of state support in some cases, in particular, this applies to direct investment in the countries of the Eurasian Union. However, in the concept proposed by the author of the work, these measures are not considered, due to the fact that they can be applied within the framework of the Russian Agency for export credit and investment insurance (EXIAR).
The concept proposed by the author is based on the statement that the strengthening of state regulation of the process of capital export will reduce its volume
in the medium term, which will increase the rate of gross accumulation in the country in the near future. Strengthening of this regulation should be carried out primarily through the statements of the owners of the exported previously exported capital. With the deterioration of a number of macroeconomic indicators, quantitative restrictions should be applied, along with the reporting of capital exporters.
To implement this concept is determined to make changes to the legislation of the Russian Federation:
1. In the Federal law «on currency regulation and currency control» №. 175 -FL of services 10.12.2003 article 8 «regulation of levers by the Central Bank of the Russian Federation of currency operations of capital movements», canceled in 2006, giving the Central Bank the right to maintain special accounts. In this case, special accounts should be introduced on the basis of the operation on the export of capital abroad, whereas in the previous version of this article, the quantitative prohibition applied only to operations related to external lending and purchase and sale of securities, and accompanied by a requirement for the final beneficiaries to provide systematic reporting on the movement of exported funds. Special account needs to be opened to the previously exported assets, including the illegally exported capital in the framework of the amnesty;
2. Make the above article the requirement of the Central Bank to the residents of the Russian Federation to reserve up to 100% of the exported amount for up to 2 years. This reservation is possible automatically with the deterioration of macroeconomic indicators such as:
3. - formation of a negative balance of the current balance of the country;
4. - increase of capital exports by more than 25 %;
5. - reduction of foreign exchange reserves by more than 25 %;
6. - the fall of the national currency (ruble) by more than 25 %;
7. - the excess of payments on foreign debt in relation to exports of goods and services by 51 %.
3. Amendments to article 10 of the Federal law «on the basis of state regulation of foreign trade activities» № 164-FL dated 08.12.2003, which allows both residents and non-residents of the Russian Federation to carry out foreign trade activities. Today, guided by this provision, one - day firms conduct questionable operations. In this regard, the right to conduct foreign trade operations firms with 2 years of experience
in operations in the domestic market with an annual turnover of at least 3 million rubles.
Thus, the proposed concept gives the Bank of Russia the functions of a megaregulator in the field of capital exports from Russia abroad. The implementation of this concept does not require changes and additions in the Federal law «On the Central Bank of the Russian Federation (Bank of Russia) № 86 - FL of 10.07.2002 g. the Concept proposes to restore and enhance the regulation of the Bank of Russia of export of capital abroad. Article 7 of the Federal law» on the Bank of Russia» says that: «the Bank of Russia on matters within its competence... issues normative acts in the form of instructions, regulations and instructions» for Russian residents. For this reason, the regulation of capital exports from the country could be based on such regulations.
Above in the work it was proposed to regulate the export of capital in two types:
- In a constant mode in order to increase the transparency of capital exports;
- In emergency mode with a sharp deterioration of macroeconomic indicators.
On a permanent basis, the Central Bank can use special accounts for exporters as follows:
- Introduce a requirement that all exporters of capital are required to provide information about the ultimate beneficiaries;
- Introduce a requirement for systematic (semi-annual) reporting by these beneficiaries on the subsequent movement of the exported funds;
- Application of this practice to previously exported capital, including through obtaining information about the final beneficiaries from foreign financial authorities and from the beneficiaries themselves (in the latter case, it will be necessary to work out the issue of Amnesty for previously exported capital illegally).
In the emergency mode, in addition to the use of special accounts, reservation of up to 100% of the exported amount for up to 2 years is offered. At the discretion of the Central Bank reservation can be extended to such forms \export of capital as:
- Portfolio investments and derivatives, with the exception of securities quoted on MICEX;
- Loans and borrowings, as well as balances on current accounts and deposits in foreign banks, the amount of which exceeds the export standards established by the CBR.
Thus, we come to the following conclusions:
• In order to prevent capital outflows, it is necessary, by contrasting domestic capital investments as a competitive alternative to capital outflows, not only to reduce the overall tax burden, but also to make changes in the structure of the tax system, including the reintroduction of an investment benefit on income tax, and to maximize its effectiveness, to concentrate it in the points of economic growth, as well as to use the mechanism of tax credit. While improving the quality of documentary audits conducted by tax authorities, strengthening tax discipline and responsibility, developing effective methods of control and collection. The tax authorities should not only identify the facts of concealment of income and tax evasion, including through «offshore schemes», but also promptly cover possible channels of tax violations by improving the regulatory framework;
• The greatest efficiency of the regulatory impact of the system of instruments for the implementation of the strategy of state regulation of the export of capital abroad is manifested when the whole set of economic methods and forms is used;
• The ability of the state to use the instruments of capital export regulation is limited. Due to the fact that currently used a small number of methods and forms of appropriate regulation;
• To increase the efficiency and flexibility of the policy of state regulation of capital outflow in order to achieve the course of strategic economic development goals, it is necessary to use a wider range of tools (methods and forms);
• The problem of capital outflow abroad, both in legal and illegal forms, will exist until a certain stability is established in the country, in the economy, in law, until potential domestic investors believe in the reliability of the budget, tax, legal, institutional systems of the country. The failure of the state in the near future to take urgent legal, financial, economic measures to improve the Russian economy, to block the channels of illegal export of capital abroad can lead to further export of capital from Russia, a new financial shock;
• The issue of taking practical measures to attract previously exported capital to the Russian economy is being actualized. One of the controversial issues in this case is the issue of Amnesty of exported capital. This issue should be approached with extreme caution. We can talk about tax Amnesty for a certain period of time, but not about the capital of clearly criminal origin, for example, «laundered» and transported abroad budget money.
О
Ю
5
*
to
2 a
8
Directions of perfection of state regulation of export of capital abroad from Russia
Tabakova A.S.
Academy of labour and social relations (AL&SR)
The article is devoted to the directions of improvement of state regulation of capital export abroad from Russia. In accordance with the purpose of the work, its tasks were to assess the current situation in the field of state regulation of the export of capital from Russia, to determine the effectiveness of the use of existing legislation. In addition, the range of directions to improve the state policy in the sphere of export of capital abroad is analyzed. New directions on modernization of existing measures of state regulation of capital export are presented, as well as new opportunities for successful solution of the complex of measures of state regulation of capital export from Russia are revealed. In order to successfully solve these tasks, it is necessary not only to improve the legislative framework of the system of state regulation of the export of capital from Russia, but also to actively use the preferences obtained when entering into international trade organizations. It should be noted that all measures of state regulation of the export of capital should be considered through the prism of the national interests of the country in order to achieve a more effective result of their use. It is proved that the greatest efficiency of the regulatory impact of the system of instruments for the implementation of the strategy of state regulation of the export of capital abroad is manifested by the use of a set of economic methods and forms in an appropriate sequence.
Keywords: investment agreement, franchising, tax investments, tax credits, investment premium, customs tariff.
References
1. Antropov A. the Export of capital, the looting of
the country // Information - analytical portal Legacy.
2. Viyugin O. A. Russia and the global crisis //http:/
/www.vedomosti.ru
3. L. Grigoryev, A. Kosarev capital flight. // Economic
journal HSE. 2012, № 4
4. Dergachev, V. A., International economic
relations. Textbook for universities, M.: YUNITI-DANA, 2015.
5. Zubchenko L. International movement of capital
in modern conditions the Economist. - 2011. - No. 6
6. Kozyrev V. M. Basics of a modern economy.
Textbook - 3rd ed. Rev. and extra-M. Finance and statistics, 2015
7. Karl Marx. Capital. Vol.3. Chapter 1
8. Loungani P., Mauro P. the Outflow of capital
from Russia. // Investments in Russia. 2012. No. 7
9. Milner B. Z., Nicewicz E. V. the problem of
leakage of material and intellectual capital// proceedings of the Round table. -. M.: RAS Institute of Economics. 2016 - 171 C.
10. Smorodinskaya N. A. capital Flight as an object of international studies. The issues of economy, 2010, No. 9
11. Center for macroeconomic research (Sberbank) are the Principal causes of outflow of capital from Russia // Economy of Russia in 2017.
12. Chepurina M. N. Course of economic theory. Under the editorship of Professor, 2017
13. Cervena, Marianna. The Measurement of Capital Flight and Its Impact on Long - Term Economic Growth: Emperical Evidence from a Cross-Section of Countries // Faculty of Mathematics, Physics and Informatics of the Comenius University Bratislava. Mathematics of Economics and Finance. Bratislava, 2016.
14. Dooley M.P. and Kletzer K.M. Capital Flight, External Debt and Domestic Policies. NBER, 2004.
15. Erkin B., Ocampo J.A. Capital Account Regulations, Foreign Exchange Pressure, and Crises Resilience. April 2017.
16. Feldstein M. and Horioka C. Domestic Saving and International Capital Flows // Economic Journal, 2000, № 90.
17. IMF. Liberalizing Capital Flows and Managing Outflows. March, 2017.
18. OECD. Code of Liberalization of Capital Movements. 2013.
19. Obstfeld M. and Taylor A.M. Global Capital Markets. 2017.
20. Pederson, Jorden Dige. Political Factors Behind the Rise of Indian Multinational Enterprises: An Essay in Political Economy // Sauvant Karl, Pradhan P. The Rise of Indian Multinationals, 2011.
21. Reinhart C. and Reinhart V. "Capital Flow Bonanzas" in J. Frankel and F. Jiavazzi. International Seminar in Macroeconomics. Chicago, 2017.
22. Shneider, Benu. Measuring Capital Flight: Estimates and Interpretations // Overseas Development Institute Working Paper 194. March 2013.
23. Storm Survivors. Special Report. Offshore Finance // The Economist. February 16-th 2015.
24. The Internationalization of Yen and Key Currency Questions // IMF Working Paper, wp/94/41, April 2004.
25. UNCTAD. World Investment Report 2017. New York and Geneva. 2017.
26. Yalta, Yasmin A. Effects of Capital Flight on Investment: Evidence from Emerging Markets // Emerging Markets Finance and Trade. November/December 2016. Vol.46. Issue 6. P. 46-51.
27. www.gks.ru - Official website of the Federal state statistics service
28. www.gks.ru - Official website of the Federal state statistics service
сч cn £
6 a
2 ©
