Summary
Full Decision
ARBITRAL DECISION
A – REPORT
1. A..., SA., legal entity no. ..., with registered address at Rua ..., no. ..., ...-... Lisbon, filed, on 03-10-2018, a request for constitution of the arbitral tribunal, pursuant to articles 2º and 10º of Decree-Law no. 10/2011, of 20 January (Legal Framework of Arbitration in Tax Matters, hereinafter referred to simply as RJAT), in conjunction with article 102º of the Code of Tax Procedure and Process (CPPT), in which the Tax and Customs Authority (hereinafter referred to simply as the Respondent, or ATA) is requested.
2. The Claimant seeks, with its request, the declaration of illegality of ninety-eight acts of assessment of the Single Circulation Tax, relating to the years 2014, 2017 and 2018, in the total amount of 9,557.44 €, plus compensatory interest, as well as the acts dismissing gracious complaints filed, and the respective acknowledgement of the right to compensatory interest.
3. The request for constitution of the arbitral tribunal was accepted by the President of CAAD and automatically notified to the Tax and Customs Authority on 04-10-2018.
3.1. The Claimant did not proceed with the appointment of an arbitrator, wherefore, under the provisions of article 6º, no. 2, paragraph a) and article 11º, no. 1, paragraph b) of the RJAT, the President of the Ethics Council appointed the undersigned as arbitrator of the arbitral tribunal, who communicated acceptance of the appointment within the respective deadline.
3.2. On 22-11-2018 the parties were notified of the arbitrator's appointment, and no impediment was raised.
3.3. In conformity with the provisions of article 11º, no. 1, paragraph c) of the RJAT, the arbitral tribunal was constituted on 12-12-2019.
3.4. In these terms, the Arbitral Tribunal is regularly constituted to examine and decide the subject matter of the proceedings.
4. In support of the request for arbitral pronouncement, the Claimant alleges, in summary, the following:
It is a credit institution in which, among its areas of activity, special relevance is assumed by financing of the automotive sector, a substantial part of its activity is related to the execution of – among others – financial leasing contracts ("LSG") intended for the acquisition, by companies and individuals, of motor vehicles.
The motor vehicles to which the assessments which are the subject of the arbitral request refer were given in financial leasing and ALD.
Almost all customers in those contracts acquired, at the end of the respective contract, the motor vehicle which was the subject thereof, by means of payment of the residual value of the leased asset, plus expenses and VAT.
With regard to vehicles with the registrations ... and ..., by express indication of the lessee or due to the existence of assignment of the contractual position, it was not the original holders of the financial leasing contracts who came to acquire the vehicles.
And, on the other hand, with respect to vehicles with the registrations ... and ..., due to total loss, as a consequence of a loss event which occurred before the end of the respective contract, the vehicles were transferred to the Insurance Company.
In the relevant months of the years to which the tax acts under analysis relate, the Claimant cannot be held responsible for the payment of IUC, as it was no longer the owner of the vehicles to which the tax assessments refer.
If arbitral case law has mainly emphasized that even during the term of an LSG or ALD, the lessor entity should not be considered the taxable person of IUC, by extension it should even less so be attributed the subjective incidence of that tax when, after the end of the contract, the lessee exercises its right to acquire the leased asset at the residual value, plus expenses and VAT.
Registration is neither a condition of validity of the contract of sale nor a condition for the production of the transfer effect thereof, wherefore its absence does not affect the quality of owner nor affects the full efficacy of such contract vis-à-vis the AT, as it does not have the quality of third party for registration purposes.
The presumption derived from vehicle registration cannot but be understood as a rebuttable presumption, in particular by virtue of the provisions of article 73º of the LGT, by always admitting proof to the contrary.
Sufficient proof for such rebuttal is embodied in the invoices of sale of the motor vehicles, which is sufficient to attest the sale of all vehicles contained in the tax assessments to the respective acquirers.
The Claimant therefore concludes by the illegality of the assessments which are the subject of the arbitral request, as well as the aforementioned dismissal orders, also claiming the right to compensatory interest and to hold the Respondent liable for the costs of the proceedings.
5. In turn, the Respondent replied by alleging, in summary:
The tax legislator, in establishing in article 3º, no. 1 who the taxable persons of the IUC are, expressly and intentionally established that these are the owners (or in the situations provided for in no. 2, the persons listed there), being considered as such the persons in whose name they are registered.
It emphasizes that the legislator did not use the expression "it is presumed", as it could have done, for example, in the following terms: "the taxable persons of the tax are the owners of the vehicles, being presumed as such the natural or legal persons, of public or private law, in whose name they are registered."
The tax provision is full of provisions analogous to that enshrined in the final part of no. 1 of article 3º, in which the tax legislator, within its freedom of legislative formulation, expressly and intentionally, establishes what must be considered legal, for purposes of incidence, of income, of exemption, of determination and of periodization of taxable profit, for purposes of residence, of location, among many others.
In light of the wording of the provision, it is manifestly not possible to invoke that it is a presumption, as the claimant maintains. Rather, it is a clear option of legislative policy embraced by the legislator, whose intention, within its freedom of legislative formulation, was that, for the purposes of IUC, those who appear as such in the vehicle register should be considered owners.
The claimant's claim is based on an equivocation and results from an interpretation that does not take into account the systemic element, violating the unity of the regime enshrined in the entire CIUC and, more broadly, in the entire legal-tax system and, finally, stems from an interpretation that ignores the rationale of the regime enshrined in the article in question, and also in the entire CIUC.
It clarifies that the failure to update the registration, in accordance with the provisions of article 42º of the Regulation of the Vehicle Register, will be imputable in the legal sphere of the taxable person of the IUC and not of the Portuguese State, as the active subject of this tax.
In light of a teleological interpretation of the regime enshrined in the entire CIUC, the interpretation advocated by the claimant to the effect that the taxable person of the IUC is the owner or the financial lessee (even if the registration of that quality does not appear in the vehicle register) is manifestly wrong, inasmuch as the very rationale of the regime enshrined in the IUC Code constitutes clear evidence that what the tax legislator intended was to create a Single Circulation Tax based on the taxation of the owner of the vehicle as it appears in the vehicle register.
The documents attached by the Claimant to rebut the presumed presumption do not prove in a clear and unequivocal manner that the transfer of the vehicle and consequently of its ownership occurred, with not a single bank statement or cheque being attached that proves that the invoices were paid or that the contracts were fulfilled, in addition to the fact that invoices are not apt to prove the execution of a synallagmatic contract.
It maintains that the tax acts in question are valid and legal, because they conform to the legal regime in force at the date of the tax facts, wherefore no error attributable to the services occurred, in casu, further arguing that in no circumstance are the legal prerequisites that confer the right petitioned to compensatory interest met.
6. On 20-03-2019 the meeting referred to in article 18º of the RJAT took place, and the witness called by the Claimant was examined, by means of the statement of the illustrious legal representatives of the Respondent that they dispensed with the examination of the same as they understood that "... the evidence produced is not admissible in light of the reasons set out in the previous submissions...", in sum, for understanding that the production of witness evidence is not admissible for the facts in question.
7. Having been granted a deadline for the submission of written submissions, both parties did so, maintaining the positions previously held, with the Claimant submitting a response to those submitted by the Respondent, with the order being made for its removal from the file.
* * *
PRELIMINARY DETERMINATION
The Arbitral Tribunal was regularly constituted and is materially competent.
The parties enjoy legal personality and capacity and are legitimate (articles 4º and 10º, no. 2, of the RJAT and article 1º of Ordinance no. 112-A/2011, of 22 March).
The cumulation of claims is legal (article 3º, no. 1 of the RJAT).
B. DECISION
1. FACTUAL MATTER
1.1. PROVEN FACTS
Taking into account the positions assumed by the parties, the documentary evidence attached to the file and the witness evidence produced – bearing in mind that the Tribunal has no duty to rule on all the matters alleged, having rather the duty to select those that matter for the decision, taking into account the cause of action that substantiates the claim filed [cfr. articles 596º, no. 1 and 607º, nos. 2 to 4, of the Civil Procedure Code, as amended by Law 41/2013, of 26/6, and to record whether it considers them proven or not proven (cfr. article 123º, no. 2, of the CPPT)] - the following facts are considered proven, with relevance for the examination and decision of the issues raised:
a) The Claimant is a credit institution, assuming special relevance, in its commercial activity, the financing of the automotive sector, in particular through the execution of financial leasing contracts and long-term rental contracts.
b) The Claimant was notified of ninety-eight IUC assessments, one relating to the year 2014, fifty-nine relating to the year 2017 and thirty-eight relating to the year 2018, in accordance with Annex A attached to the initial request.
c) The Claimant filed gracious complaints regarding the IUC incident on the registrations ..., referring to the year 2017 and ..., referring to the same year 2017.
d) In both gracious complaint procedures, dismissal orders were issued, both dated 30-08-2018.
e) The Claimant issued sales invoices with respect to all motor vehicles to which the assessments that are the subject of the present proceedings refer, before the date to which they refer.
d) The Claimant proceeded with the payment of the tax to which the present proceedings refer.
1.2 The facts were established as proven based on the critical analysis of the documents attached to the proceedings by the Claimant and by the testimony of witness B... which we consider to be consistent and credible.
1.3 UNPROVEN FACTS
There are no facts established as unproven with relevance for the examination of the claim.
1.4 THE LAW
The substantive issue to be examined in the present proceedings resides, on one hand, in the interpretation to be given to no. 1 of article 3º of the CIUC in order to ascertain whether the rule of subjective incidence, contained therein, establishes a legal presumption juris tantum – and, as such, susceptible to rebuttal – or whether, on the contrary, it contains an express and intentional definition of personal incidence, in the sense that necessarily the taxable person of the tax is the one in whose name the motor vehicle is registered as owner.
It being necessary to bear in mind, given that the assessments refer to different years, that, in the time period in question – 2014 to 2018 – that legal rule was the subject of legislative amendment through Decree-Law 41/2016, of 1 August, which entered into force on 02-08-2016.
Article 3º, no. 1 of the CIUC, before that legislative amendment, provided that "the taxable persons of the tax are the owners of the vehicles, being considered as such the natural and legal persons, of public or private law, in whose name they are registered."
Based on the wording of this provision, the Respondent - AT - maintains that the personal incidence basis that this defines contains no legal presumption, since that provision conveys in an express and intentional manner the thought of the tax legislator, in the sense of considering, in an irrebuttable manner, as taxable persons of the IUC the persons in whose name the motor vehicles were registered.
It argues in support of its thesis, hermeneutical reasons of interpretation of the law, appealing not only to its literality, but also to the systemic and teleological elements.
An invocation full of meaning, inasmuch as, according to the provisions of article 11º of the LGT, "in determining the meaning of tax rules and in qualifying the facts to which they apply, the general rules and principles of interpretation and application of laws are observed". For, as mentioned by Diogo Leite Campos, Benjamim Rodrigues, J. Lopes de Sousa – LGT 4th ed., in annotation to such article, "... without departing from the letter of the law, which must be the interpreter's main reference and starting point, its automatic application is excluded, assuming that in laws there is an operative rationality that the interpreter must strive to reconstruct".
It is, therefore, within this framework of interpretation of tax law, in this case article 3º, no. 1 of the CIUC, that we must find the answer to the antagonism of positions between the Claimant and the AT.
For the Respondent, it is decisive for the determination of the taxable person of the IUC the registration of ownership of the motor vehicle, so that it will be considered as such, in an irreversible manner, the one in whose name it is registered.
The registration of ownership of vehicles is, in light of the provisions of article 5º, no. 1, a) and no. 2 of Decree-Law 54/75, of 12 February, compulsory, so that any right of ownership that affects the vehicle is subject to registration, with which the security of legal commerce is sought, as well as the publicity of the legal situation thereof.
Such registration enjoys, according to the provisions of article 7º of the Land Registry Code (applicable to vehicle registration by virtue of article 29º of the aforementioned Decree-Law 54/75), the "... presumption that the right exists and belongs to the registered holder, in the precise terms in which the registration defines it".
We therefore have that the inscription of vehicle ownership registration is, also, a presumption that the right of ownership over it exists in the terms contained in the registration.
That is, vehicle property registration does not constitute any condition of validity of the contracts subject to it, in the same way as occurs with land registry (whose regime, as we have already noted, is extended to vehicle registration); rather, registration has a merely declarative function.
It happens that article 5º, no. 1 of the Land Registry Code, imposes that "the facts subject to registration only produce effect against third parties after the date of the respective registration". From which it seems to follow that that would be sufficient for the AT to invoke the absence of registration to immediately set in motion article 3º, no. 1 of the CIUC, requiring the payment of the tax from the one in whose name the vehicle is registered, as the taxable person of the tax.
However, no. 4 of article 5º of the Land Registry Code restricts such understanding, by providing that "third parties, for registration purposes, are those who have acquired from a common author rights incompatible with each other". Whence it follows that, by that means, the AT would never be entitled to invoke the lack of registration, inasmuch as it does not meet the concept of third party.
Having stated this in general terms, it is necessary to ascertain whether, despite what has been mentioned, no. 1 of article 3º of the CIUC contained or not, in its original version, a legal presumption.
Everything is, in sum, to determine whether the expression "being considered", used there, had the nature of legal presumption.
Let it be said from the outset that it seems to us offensive of the unity of the legal-statutory system – and even, with due adaptations, in opposition to nos. 2 and 3 of article 11º of the LGT - that an individual come to be considered as not an owner of an asset for civil purposes and have to be necessarily so for tax purposes.
To which must be added the fact that the AT must guide its activity by observance of the principles of legality, inquisitorial and discovery of material truth, inherent to the constitutional dictate of contributory capacity.
In any case, it seems evident that, whether from a systemic or teleological point of view, the expression "being considered", adopted in no. 1 of article 3º of the CIUC unequivocally contemplates a true presumption, to which the apparent literality of the expression does not oppose, nor the tax system.
To this end, refer Diogo Leite Campos, Benjamim Rodrigues, J. Lopes de Sousa – LGT 4th ed., in annotation to article 73º, page 651: "presumptions in the matter of tax incidence can be explicit, revealed by the use of the expression "it is presumed" or similar, as occurs, for example, in nos. 1 to 5 of article 6º, in paragraph a) of no. 3 of article 10º, in articles 19º and 40º, no. 1, of the CIRS. However, presumptions can also be implicit in incidence rules, in particular of objective incidence, when certain values of movable or immovable property are considered as constituting taxable matter, in situations in which it is not unfeasible to determine the actual value ...", with a set of examples then being enumerated.
We understand that it is precisely that case which article 3º, no. 1 of the CIUC contemplates – or rather, contemplated - an implicit presumption.
It is, therefore, uncontroversial for us that article 3º, no. 1 of the CIUC enshrined a presumption of subjective incidence. It was, moreover, settled case law understanding in that sense (see, by way of merely exemplary reference, the decisions rendered in CAAD proceedings nos. 14/2013, 26/2013, 27/2013, 73/2013, 170/2013 and 154/2014 539/2016-T, 580/2016-T, 623/2016-T, 109/2017-T, 145/2017-T or 185/2017-T (omitting here the reference to decisions rendered by the undersigned in the same sense), as well as of state courts, such as the Judgments of STA of 23-05-2018 – Proc. 1341/17, TCA South of 14-03-2019 – Proc. 201/14.4BEALM or TCA South of 19-03-2015 – Proc. 08300/14 (as a footnote, it should be added that it is not understood how the Respondent insists on bringing as support for its thesis the sentence rendered by the TAF of Penafiel in proc. 210/13-0BEPNF, when it well knows that such decision was revoked by the Judgment of the STA mentioned above).
Now, no. 2 of article 350º of the Civil Code establishes that legal presumptions can be rebutted by evidence to the contrary, except in cases expressly provided for in the law.
And, with regard to the rebuttal of presumptions, we consider as good the doctrine to which the STJ resorted in the substantiation of Assento no. 1/91 of 03-04-1991 (DR no. 114, of 18 May) - to classify as juris tantum a presumption established in a labor statute - defended by Vaz Serra [Proofs (material probative law), BMJ 110-112, page 35], as well as by Mário de Brito (Annotated Civil Code, page 466) and Mota Pinto (General Theory of Civil Law, page 429): "... juris tantum presumptions constitute the rule, with presumptions jure er de jure being the exception. In case of doubt, the legal presumption is juris tantum, as it should not be considered, except reference in the law, that it was intended to prevent the production of evidence to the contrary, imposing a formal truth at the expense of the real proven".
In turn, within the scope of tax law, article 73º of the LGT provides that "the presumptions enshrined in the rules of tax incidence always admit proof to the contrary". Which means that all presumptions in the matter of tax incidence, such as that which no. 1 of article 3º of the CIUC enshrines, are juris tantum and, as such, rebuttable.
It should be said, moreover, that the Respondent too, despite the lengthy considerations made in its pleading, inclines to accept the same understanding.
But, if that was the case before the aforementioned legislative amendment, it must be ascertained whether the legislator intended that the meaning and scope of article 3º of the CIUC be different with its new wording.
Indeed, after the entry into force of the aforementioned Decree-Law 41/2016 of 1 August, no. 1 of article 3º of the CIUC took on the following wording:
- "The taxable persons of the tax are the natural or legal persons, of public or private law, in whose name the ownership of the vehicles is registered."
Not disregarding what has already been decided in previous arbitral decisions (in particular in Proc. 333/2018-T), which conclude that the new wording of that provision in no way alters the sense that it contains a mere rebuttable presumption, we reiterate here what we already sustained in the decision rendered in the context of proceedings no. 522/2018-T.
Beginning by emphasizing that the conclusion we reach does not contest the understanding above endorsed that vehicle ownership registration has a merely declarative effect and does not constitute any right.
For the new wording of no. 1 of article 3º of the CIUC does not refer, as a rule of subjective incidence, to the concept of ownership (as it did until then by saying that the taxable persons of the tax are the owners of the vehicles, being considered as such the natural and legal persons, of public or private law, in whose name they are registered), but rather to a factual delimitation: the mere existence of registration (the taxable persons of the tax are the persons in whose name the ownership of the vehicles is registered), a circumstance which we understand became the element defining the subjective incidence of the tax.
And it should be said that precisely by virtue of having now "shifted the emphasis of the tax determining the incidence of the tax to the registration" – "the taxable persons are the persons in whose name the ownership is registered" - and not to the institute of ownership itself, as then – "the taxable persons of the tax are the owners of the vehicles" -, the incidence of the tax in its current form is different from what we had before the legislative amendment. We say more. As until then the element delimiting incidence was ownership and as the registration of that same ownership has no constitutive effects but merely declarative ones, obviously that once proof was made of non-ownership, the presumption contemplated in article 3º of the CIUC would be excluded, which, for better or worse, currently does not exist.
The interpreter must apply the law starting from its literal element without neglecting the others such as historical context, teleological or the unity of the system (article 9º, no. 1 of the Civil Code), but must assume that the legislator knew how to express itself correctly (no. 2).
Now, the very preamble of Decree-Law 41/2016 justifies the amendment introduced with the "need to overcome interpretative difficulties that arose with previous wordings of this Code, it is important to clarify who is the taxable person of the tax".
Indeed, the legislator not having intended that it be otherwise, it is not seen what need for amendment or clarification the article 3º of the CIUC would lack.
It is certain that the IUC is based on the environmental and road cost of the actual use of the automobile, intending to burden taxpayers to the extent of the environmental and road cost that they cause, in implementation of a general rule of tax equality. It does so by adopting the principles, enshrined in our communitarian and even constitutional order, of the polluter-pays and equivalence. In light of such concerns of an environmental and energy nature, it would be intended that the costs arising from environmental damage caused by the use of motor vehicles be borne by the actual owners (and not by the presumed owners).
However – given the acknowledged difficulty in taxing the actual owners, arising from the non-compliance with registration obligations - in a balance and weighing of interests, the tax legislator would have intended to make the existence of registration, rather than actual ownership, prevail as the element delimiting the incidence of the tax.
We are, therefore, forced to conclude that article 3º of the CIUC, in the wording given by Decree-Law 41/2016, does not contemplate any presumption, whose rebuttal would distance it from the incidence of the tax.
Whence the IUC assessments contested in the proceedings merit no censure with reference to the years 2017 and 2018.
And what is to be said of the assessment referring to the year 2014 relating to the registration ...?
Given what has been stated, it must be ascertained whether the probative elements brought to the proceedings by the Claimant have the virtuosity of excluding the presumption established, by being proven that it was not the owner of that motor vehicle on the deadline date for payment of the respective assessment.
The Claimant attached to the proceedings an invoice evidencing the sale of vehicle ..., and the examined witness clarified the context in which such invoices are issued and how their payment is controlled. More than that, it stated that there exists a promise of purchase on the part of the lessees and authorization for direct debit for its payment.
The Respondent challenges that invoices titling contracts of sale and purchase are apt to prove the actual transfer of ownership of the vehicles. But it does not challenge the genuineness of those attached to the proceedings, but only the effects that it is intended to draw therefrom.
First and foremost, it must be emphasized that contracts for the purchase and sale of automobiles have a consensual basis and are not subject to special formalities (cfr articles 219º and 408º, no. 1, of the Civil Code) and that, as such, they can be proven by any means, including witness evidence (hence the incomprehension of the procedural stance assumed by the Respondent invoking its inadmissibility. This would only be so if what was intended to be demonstrated was the execution of financial leasing contracts – for which, those yes, written form is required – which is not the case).
Now, the invoice constitutes an accounting document prepared within the company and which is intended for external use. The invoice is to be understood as the accounting document through which the seller sends to the buyer the general conditions of the transaction carried out. It is further noted that the issuance of the invoice does not have to coincide with the actual payment of the amount to be paid by the buyer (wherefore, even if proof were not made of the actual payment of the price by the same buyer – which was not the case – the invoice constitutes proof of that same transaction, that is, of the purchase and sale effected).
Invoice which enjoys the presumption of truthfulness conferred on it by article 75º, no. 1 of the LGT, having, thus, suitability and sufficient force to rebut the presumption that supported the assessments made based exclusively on the existence of the registration.
In light of the elements carried into the proceedings by the Claimant and the facts proven, it is extracted the conclusion that it was not really the owner of the vehicle in question, having transferred before the date in which the respective IUC was due, the ownership of the same, in accordance with civil law.
From which it follows that the Claimant achieved, with total success, the rebuttal of the presumption and demonstrated that the reality of the registration was a mere appearance of that same reality, that is, the registered owner was not the actual owner.
Proven such circumstance and since the AT has no legitimacy to oppose the absence of registration, as it is not deemed a third party for such purposes, the annulment of the IUC assessment in question is imperative.
COMPENSATORY INTEREST
In addition to the restitution of the improperly paid tax, the Claimant seeks that the right to payment of compensatory interest be declared.
Such right is enshrined in article 43º of the LGT, which has as its premise that it be ascertained, in gracious complaint or judicial challenge - or in tax arbitration – that there was error attributable to the services from which results payment of the debt in an amount higher than legally due.
We follow to this end what we have already subscribed to in the Arbitral Judgment rendered in proc. 185/2017: "although it is acknowledged that the tax paid by the Claimant is not due, as it is not the taxable person of the tax obligation, determining, consequently, its respective reimbursement, it is not seen that, at its origin, there is error attributable to the services, which determines such right [to compensatory interest] in favor of the taxpayer. Indeed, by promoting the official assessment of the IUC considering the Claimant as the taxable person of this tax, the AT merely complied with the rule of no. 1 of article 3º of the CIUC, which, as abundantly mentioned above, attributes such quality to the persons in whose name the vehicles are registered.", it being certain that the Claimant did not even resort to administrative means to exclude the presumption that weighed on it.
Wherefore the Claimant has no right to the requested payment of compensatory interest regarding the paid tax.
3. DECISION
In light of the foregoing, it is decided:
a) to judge partially well-founded, on the basis of violation of law, the request for annulment of the tax acts in what respects the IUC assessment relating to the year 2014 with reference to the vehicle with the registration ...;
b) to judge unfounded the rest petitioned, absolving therefrom the Tax and Customs Authority;
c) to condemn the parties in the costs of the proceedings in proportion to their respective loss, being 914.10 € to the charge of the Claimant and 3.90 € to the charge of the Respondent.
VALUE OF THE PROCEEDINGS: In accordance with the provisions of articles 306º, no. 2 of the Code of Civil Procedure, 97º-A, no. 1, a) of the Code of Tax Procedure and Process and article 3º, no. 2 of the Regulation of Costs in Tax Arbitration Proceedings, the value of the proceedings is fixed at 9,827.65 € (fifty-one euros and forty-one cents).
COSTS: In accordance with the provisions of article 22º, no. 4, of the Regulation of Costs in Tax Arbitration Proceedings, the amount of costs is fixed at 918.00 € (nine hundred and eighteen euros), in accordance with Table I annexed to the Regulation of Costs in Tax Arbitration Proceedings.
Let it be notified.
Lisbon, 12 June 2019
The Arbitrator
António Alberto Franco
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