Summary
Full Decision
Process No. 769/2014-T
The arbitrators Dr. Jorge Lopes de Sousa (arbitrator-president), Dr. Paulo Nogueira da Costa and Dr. Luís Miranda da Rocha, designated by the Deontological Council of the Centre for Administrative Arbitration to form the Arbitral Tribunal, constituted on 30-01-2015, agree on the following:
- Report
A…, S.A., with registered office in …, …-… …, legal entity no. …, registered in the Commercial Registry Office of … under the same number (A… or claimant), in 2011 the dominant company of a group (the Group A…1) subject to the special regime for taxation of groups of companies provided for in (in the current numbering) article 69 and following of the Corporate Income Tax Code, filed a request for constitution of the collective arbitral tribunal, articles 2, no. 1, paragraph a), and 10, nos 1 and 2, of Decree-Law no. 10/2011 of 20 January (hereinafter RJAT) and articles 1 and 2 of Regulation no. 112-A/2011 of 22 March, in which the Tax and Customs Authority is respondent.
The Claimant seeks that the partial rejection of the administrative review that it submitted of the Corporate Income Tax assessment relating to the tax year 2011 be declared illegal and, furthermore, the partial illegality of the self-assessment of Corporate Income Tax, including autonomous taxation rates, of the fiscal group A…1, relating to the tax year 2011, with respect to the amount of autonomous taxation rates in Corporate Income Tax of € 443,189.22, with its consequent annulment in this part, in addition to reimbursement to the Claimant of this amount, increased by indemnity interest at the legal rate counted from 1 September 2012 until full reimbursement.
The request for constitution of the arbitral tribunal was accepted by the President of CAAD on 26-09-2014 and notified to the Tax and Customs Authority on 17-11-2014.
Pursuant to the provisions of paragraph a) of no. 2 of article 6 and paragraph b) of no. 1 of article 11 of RJAT, the Deontological Council designated as arbitrators of the collective arbitral tribunal the signatories, who communicated acceptance of the task within the applicable deadline.
On 15-01-2015 the parties were duly notified of that designation, and did not manifest any will to refuse the designation of the arbitrators, in accordance with the combined provisions of article 11, no. 1, paragraphs a) and b) of RJAT and articles 6 and 7 of the Deontological Code.
In compliance with the provision in paragraph c) of no. 1 of article 11 of RJAT, the collective arbitral tribunal was constituted on 30-01-2015.
The Tax and Customs Authority responded, defending the lack of merit of the request for arbitral determination.
By ruling of 03-03-2015, it was decided to dispense with the meeting provided for in article 18 of RJAT and that the proceeding continue with written submissions.
The parties submitted written submissions.
The parties have legal standing and capacity, are legitimate and are duly represented (arts. 4 and 10, no. 2, of the same statute and art. 1 of Regulation no. 112-A/2011, of 22 March).
The proceeding is not affected by any nullities and there is no obstacle to the examination of the merits of the case.
- Facts
2.1. Proven facts
The following facts are considered proven:
a) The Claimant was, in 2011, the dominant company of a group of companies (the Group A…1) subject to the special regime for taxation of groups of companies (RETGS);
b) The Claimant submitted, on 28-05-2012, its aggregate declaration of Corporate Income Tax Form 22 relating to the tax year 2011, having at that time proceeded to self-assess the said tax (including the resulting surcharge), and on 30-08-2012 and 31-12-2013, further submitted amendments to that self-assessment by submitting replacement declarations (Documents nos. 1, 2 and 3 attached with the request for arbitral determination, whose contents are incorporated by reference);
c) The amount of Corporate Income Tax, including autonomous taxation rates, and the resulting surcharge, self-assessed, is paid;
d) The Corporate Income Tax declaration form in the information system of the Tax and Customs Authority did not allow the Claimant to deduct, within the limits of the Corporate Income Tax collection, including autonomous taxation rates, the amounts of tax benefit recognized to the companies of the fiscal group A…1 under the Tax Incentives System for Research and Development (SIFIDE);
e) In the last declaration submitted, the fiscal group A…1 presented SIFIDE available for use of € 6,073,504.27 (Field 712 of table 073 of Annex D, of Declaration Form 22 relating to the tax year 2011, a copy of which constitutes Document no. 3 attached with the request for arbitral determination, whose content is incorporated by reference);
f) With the additional Corporate Income Tax assessment relating to the tax year 2011, in which there was an additional use of SIFIDE of € 2,212,648.38 (Document no. 12 attached with the request for arbitral determination, whose content is incorporated by reference), there remained unused with respect to the same tax year 2011, € 3,860,856.62 in tax credit for SIFIDE;
g) This amount is no longer entirely available for use in 2011 because, in the administrative review relating to the tax year 2011, the deduction of € 392,196.76 (self-assessed Corporate Income Tax) and € 213,130.56 (additional Corporate Income Tax assessment), totaling € 605,327.32, was granted to the state surcharge collection of the tax year 2011 (Document no. 5 attached with the request for arbitral determination, whose content is incorporated by reference), there now remain, with respect to the tax year 2011, € 3,255,529.30 (€ 3,860,856.62 – € 605,327.32) for potential deduction to the collection of autonomous taxation rates in Corporate Income Tax;
h) The autonomous taxation rates relating to the year 2011 are in the amount of € 443,189.22 (documents nos. 2 and 3 attached with the request for arbitral determination, whose contents are incorporated by reference);
i) On 21-05-2014, the Claimant submitted an administrative review having as its subject the self-assessment relating to the tax year 2011 and the additional Corporate Income Tax assessment relating to the tax year 2011, with no. 2014 …, and was rejected by ruling of 20-08-2014, of the Head of the Division for Tax Management and Assistance of the Large Taxpayers Unit, in the part in which the Claimant intended to deduct SIFIDE tax credit of € 443,189.22 from the collection of autonomous taxation rates in Corporate Income Tax (documents nos. 4 and 5 attached with the request for arbitral determination, whose contents are incorporated by reference);
j) The Claimant was notified on 25-08-2014, of the decision rejecting in part the administrative review (document no. 5 attached with the request for arbitral determination, whose content is incorporated by reference);
k) The taxable profit of the Fiscal Group A…1 and its respective companies, relating to the tax year 2011, was not determined by indirect methods (documents nos. 1, 2 and 3, attached with the request for arbitral determination, whose contents are incorporated by reference);
l) The companies comprising the group A…1 that generated the tax benefit of SIFIDE are not and were not at that time debtors to the State and to social security of any taxes or contributions (document no. 13 attached with the request for arbitral determination, whose content is incorporated by reference);
m) On 16-11-2014, the Claimant submitted the request for constitution of the arbitral tribunal that gave rise to the present proceeding.
2.2. Unproven facts
There are no facts relevant to the decision that have not been proven.
2.3. Rationale for the establishment of the facts
The facts were considered proven on the basis of the documents attached with the request for arbitral determination and the administrative proceeding, with no controversy regarding them.
With respect to the information system, the Tax and Customs Authority does not contest that it does not permit deduction of SIFIDE credits from Corporate Income Tax collection; rather, it argues that this is the appropriate functioning (article 49 of the response).
- Legal Issues
In 2011, the Tax Incentives System for Research and Development II (SIFIDEII) was in effect, which was approved by article 133 of Law no. 55-A/2010, of 31 December.
This statute establishes the following in its articles 4 and 5:
Article 4
Scope of the deduction
1 - Portuguese resident Corporate Income Tax taxpayers who engage, whether as their principal activity or not, in an activity of agricultural, industrial, commercial or service nature, and non-residents with a permanent establishment in that territory, may deduct from the amount determined under article 90 of the Corporate Income Tax Code, and up to the amount thereof, the value corresponding to research and development expenses, in the part that has not been subject to financial participation by the State on a non-refundable basis, realized in the tax periods from 1 January 2011 to 31 December 2015, at a dual percentage:
a) Base rate - 32.5% of expenses incurred in that period;
b) Incremental rate - 50% of the increase in expenses incurred in that period compared to the simple arithmetic average of the two preceding years, up to the limit of (euro) 1,500,000.
2 - For Corporate Income Tax taxpayers who are SMEs according to the definition contained in article 2 of Decree-Law no. 372/2007, of 6 November, that have not yet completed two tax years and that have not benefited from the incremental rate set out in paragraph b) of the preceding number, a 10% increase is applied to the base rate set out in paragraph a) of the preceding number.
3 - The deduction is made, pursuant to article 90 of the Corporate Income Tax Code, in the assessment relating to the tax period mentioned in the preceding number.
4 - Expenses that, due to insufficient collection, cannot be deducted in the year in which they were incurred may be deducted up to the sixth immediately following year.
5 - For purposes of the preceding numbers, when in the year of beginning of enjoyment of the benefit there is a change in the tax period, the annual period that begins in that year should be considered.
6 - The incremental rate provided for in paragraph b) of no. 1 is increased by 20 percentage points for expenses related to hiring doctorates by companies for research and development activities, with the limit provided in the same paragraph becoming (euro) 1,800,000.
7 - To taxpayers who reorganize, as a result of concentration operations as defined in article 73 of the Corporate Income Tax Code, the provisions of no. 3 of article 15 of the Tax Benefits Statute apply.
Article 5
Conditions
Only taxpayers of Corporate Income Tax who cumulatively meet the following conditions may benefit from the deduction referred to in article 4:
a) Their taxable profit is not determined by indirect methods;
b) They are not debtors to the State and to social security of any taxes or contributions, or have payment thereof duly assured.
The Claimant argues, in summary, that if the collection of autonomous taxation rates is considered as Corporate Income Tax collection, it is relevant for deduction of SIFIDE tax credits and that the Tax and Customs Authority has already recognized this in a decision regarding another taxpayer on similar subject matter.
The Tax and Customs Authority argues, in summary, that the amounts representing SIFIDE are deducted from the amounts determined under article 90 of the Corporate Income Tax Code, and up to the amount thereof, that, in the absence or insufficiency of collection, determined in those terms, expenses that cannot be deducted in the year in which they were realized may be deducted up to the 6th immediately following year, and that the collection referred to in article 90, when the assessment is to be made by the taxpayer (the situation occurring in this case), is determined on the basis of the taxable matter contained in the declaration in which that assessment is expressed, that is, in the self-assessment, pursuant to article 90, no. 1, paragraph a) of CIRC. The Tax and Customs Authority further argues that "illustrative of the circumstance that the credit representing SIFIDE is deducted, and only, from the collection thus determined, that is, from the collection determined on the basis of the taxable matter, is the provision of article 5, paragraph a), of the law governing SIFIDE, which prevents the credits deriving therefrom from being deducted when taxable profit is determined by indirect methods and autonomous taxation rates are determined autonomously and distinctly from the determination carried out pursuant to the provisions of article 90 of CIRC. The Tax and Customs Authority further states that, contrary to the provisions of article 12 and paragraph a) of no. 1 of article 23-A of CIRC, in nos 1 and 2 of article 90 there is no reference to autonomous taxation rates, which, in itself, given the dual nature of the system, raises well-founded objections to considering the amount of autonomous taxation rates for purposes of the deductions provided for in no. 2 of the cited article 90, and that it would be contrary to the spirit of the system to permit that, by force of the deductions referred to in no. 2 of article 90 of CIRC, there be removed, or at least undermined, from autonomous taxation rates the anti-abuse character that presided over their implementation in the Corporate Income Tax system. As to the decision regarding another taxpayer referenced by the Claimant, the Tax and Customs Authority argues that the issue raised here by the Claimant was not examined. With respect to the information system, the Tax and Customs Authority argues that it functions appropriately by not permitting the deduction of SIFIDE credits from Corporate Income Tax collection derived from autonomous taxation rates.
Therefore, the essential issue that is the subject of this proceeding is whether the tax credits that, in the year 2011, were recognized to the Claimant, in the context of SIFIDE, may be deducted from the collection produced by the autonomous taxation rates that burdened it in that tax year, in the part in which they cannot be deducted from the remaining Corporate Income Tax collection.
There are autonomous taxation rates provided for in CIRC (article 88 of CIRC) and autonomous taxation rates provided for in CIRS (article 73 of CIRS).
The collection provided by them constitutes collection of the respective tax, and is subject to the generality of rules provided for in the codes referred to, potentially applicable.
As for Corporate Income Tax, in addition to the unanimity of case law, article 23-A, no. 1, paragraph a), of CIRC, in the version of Law no. 2/2014, of 16 January, leaves no room for any reasonable doubt, corroborating what previously resulted from the literal wording of article 12 of the same Code.
However, the solution to this conceptual question of the nature of the collection derived from autonomous taxation rates provided for in CIRC does not permit resolution of the question of whether credits derived from SIFIDE can be deducted from that same collection.
In fact, the statute that approved SIFIDE does not state that the credits deriving therefrom are deductible from all and any Corporate Income Tax collection; rather, it defines the scope of the deduction by referring, in no. 1 of article 4, "to the amount determined under article 90 of the Corporate Income Tax Code, and up to the amount thereof".
No. 3 of the same article confirms that it is the amount determined under article 90 of CIRC that is relevant to effectuate the deduction by stating that "the deduction is made, pursuant to article 90 of the Corporate Income Tax Code, in the assessment relating to the tax period mentioned in the preceding number".
Thus, the question of interest to resolve is, regardless of the nature of the tax to which autonomous taxation rates relate, whether the amount of autonomous taxation rates is "determined under article 90 of CIRC", for if it is, it must be concluded that, to determine the limit of the deduction, account is taken of the collection derived from autonomous taxation rates.
Article 90 of CIRC refers to the forms of assessment of Corporate Income Tax, by the taxpayer or by the Tax Administration, applying to the determination of the tax due in all situations provided for in the Code, including additional assessment (no. 10).
Therefore, it also applies to the assessment of the amount of autonomous taxation rates, which is determined by the taxpayer or by the Tax Administration pursuant to article 90 of CIRC, there being no other provision that provides for different terms for its assessment. Their autonomy is limited to the applicable rates and to the respective taxable matter, but the determination of their amount is carried out pursuant to article 90.
The differences between the determination of the amount resulting from autonomous taxation rates and that resulting from taxable profit are based on the determination of the taxable matter and on the rates, provided for in Chapters III and IV of CIRC, but not on the forms of assessment, which are provided for in Chapter V of the same Code and are of common application to autonomous taxation rates and to the remaining Corporate Income Tax taxable matter.
Therefore, since it is to article 90, inserted in this Chapter V, that is referred to in article 4, no. 1, of SIFIDE, there is no legal support for making a distinction between the collection derived from autonomous taxation rates and the remaining Corporate Income Tax collection, by the fact that the rates and the forms of determination of the taxable matter are distinct.
The fact, invoked by the Tax and Customs Authority, that article 5 of SIFIDE excludes the benefit when taxable profit is determined by indirect methods and autonomous taxation rates include situations in which it aims indirectly at the taxation of profits (namely, by not giving relevance to or discouraging facts susceptible of reducing them), has no relevance for this purpose, for the concept of "indirect methods" has a precise scope in tax law, which is effectuated in article 90 of LGT (in addition to special rules), relating to means of determining taxable profit whose use is not provided for in the calculation of the taxable matter of autonomous taxation rates provided for in article 88 of CIRC.
On the other hand, if it is the necessity of making use of indirect methods that excludes the possibility of enjoying the benefit, one cannot justify that exclusion with respect to the collection of autonomous taxation rates determined by direct methods.
Furthermore, one cannot see, in the eventual nature of anti-abuse rules assumed by some autonomous taxation rates, an explanation for their exclusion from the respective collection from the scope of deductibility of the SIFIDE benefit, for there is no legal support for excluding deductibility from collection provided by corrections based on rules of an indisputably anti-abuse nature, such as, for example, those relating to transfer pricing or undercapitalization.
Nor is it apparent how it can be relevant, to exclude the deductibility of the benefit from the global Corporate Income Tax collection, the hypothetical finding that, at the time the CIRC was drafted, the respective collection would always result from application of the rate to taxable profit, determined and corrected pursuant to the Code. Indeed, as stated, it is manifest that this is not the case at the time SIFIDE was drafted, and it is article 4 of this statute that defines the collection relevant for application of the tax benefit.
Nor is it apparent how from the fact, mentioned by the Tax and Customs Authority in its submissions, that the deductibility of the SIFIDE tax benefit is "expressly limited to the collection of article 90 of CIRC, up to the amount thereof" one can conclude that "the tax credit will only be deductible if there is taxable profit", for what that fact requires is that there be Corporate Income Tax collection, which can exist even without taxable profit, namely due to autonomous taxation rates.
It is true that, as the Tax and Customs Authority states, autonomous taxation rates aim to discourage certain taxpayer behaviors susceptible of affecting taxable profit and their deterrent force will be attenuated with the possibility of the respective collection being subject to deductions.
But, it is also true that, as is inherent in that statement, those autonomous taxation rates only aim to protect or increase tax revenues and tax benefits granted, by definition, are "measures of an exceptional character instituted for the protection of relevant extrafiscal public interests that are superior to those of taxation itself which they prevent" (article 2, no. 1, of EBF).
And, in the case of the SIFIDE tax benefits, the reasons of an extrafiscal nature that justify their precedence over tax revenues are, from a legislative perspective, of enormous importance, as appears from the fact that these benefits are indicated as being specially excluded from the general limit to the relevance of tax benefits in Corporate Income Tax, indicated in article 92 of CIRC.
Therefore, it is certain that we are dealing with tax benefits whose justification is legislatively considered more relevant than the attainment of tax revenues, inferring from that article 92 that the legislative intention to incentivize investments in research and development provided for in SIFIDE is so firm that it goes to the point of not even establishing any limit to the deductibility of Corporate Income Tax collection, despite this tax regime having been created and applied in a period of notorious difficulties in public finances.
Therefore, there is no legal foundation, namely in light of the legislative intention that can be detected, for excluding the deductibility of the SIFIDE tax benefit from the collection of autonomous taxation rates that results directly from the letter of article 4, no. 1, of the respective statute, combined with article 90 of CIRC.
Accordingly, it is concluded that the self-assessment of Corporate Income Tax of the fiscal group A…1, relating to the tax year 2011, in the part in which deduction was not made of the amounts referring to SIFIDE to the amount of autonomous taxation rates, is affected by a defect of violation of law, which justifies its annulment, the same occurring with the decision of the administrative review, in the part in which it did not recognize that illegality.
- Reimbursement of amounts paid and indemnity interest, counted from 1 September 2012
The Claimant further requests reimbursement of the amount of € 443,189.22, which it paid, corresponding to the amount of autonomous taxation rates on which the SIFIDE tax benefit can be deducted.
The Claimant further requests indemnity interest for the unduly paid amount of that amount from 01-09-2012, the day following the end of the deadline for automatic reimbursement of tax (article 104, no. 3, of CIRC, in the version in effect in 2012).
In accordance with the provisions of paragraph b) of art. 24 of RJAT, the arbitral decision on the merits of the claim, which is not subject to appeal or challenge, binds the Tax Administration from the end of the deadline provided for an appeal or challenge, and the latter must, in the exact terms of the success of the arbitral decision in favor of the taxpayer and until the end of the deadline provided for the execution of judgments of the judicial tax courts, "restore the situation that would exist if the tax act that is the subject of the arbitral decision had not been performed, adopting the acts and operations necessary for the purpose", which is in keeping with the provision of art. 100 of LGT [applicable by force of the provision of paragraph a) of no. 1 of art. 29 of RJAT] which establishes that "the tax administration is obliged, in case of success in whole or in part of an administrative review, judicial challenge or appeal in favor of the taxpayer, to the immediate and complete restoration of the legality of the act or situation that is the subject of the dispute, including the payment of indemnity interest, if applicable, from the end of the deadline for execution of the decision".
Although art. 2, no. 1, paragraphs a) and b), of RJAT uses the expression "declaration of illegality" to define the jurisdiction of the arbitral tribunals that function in CAAD, not making reference to sentencing decisions, it should be understood that the powers that, in judicial challenge proceedings, are attributed to the tax courts, are included in their jurisdiction, this being the interpretation that is in keeping with the meaning of the legislative authorization on which the Government based itself to approve RJAT, in which it is proclaimed, as the first directive, that "the tax arbitral process must constitute an alternative procedural means to the judicial challenge process and to the action for recognition of a right or legitimate interest in tax matters".
The judicial challenge proceeding, despite being essentially a proceeding for annulment of tax acts, allows condemnation of the Tax Administration in the payment of indemnity interest, as appears from art. 43, no. 1, of LGT, in which it is established that "indemnity interest is due when it is determined, in administrative review or judicial challenge, that there was error attributable to the services from which resulted payment of the tax debt in amount superior to that legally due" and art. 61, no. 4 of CPPT (in the version given by Law no. 55-A/2010, of 31 December, which corresponds to no. 2 in the initial version), which states that "if the decision recognizing the right to indemnity interest is judicial, the deadline for payment is counted from the beginning of the deadline for its automatic execution".
Thus, no. 5 of art. 24 of RJAT, in stating that "payment of interest, regardless of its nature, is due pursuant to the provisions of general tax law and the Tax Procedure and Process Code", should be understood as permitting recognition of the right to indemnity interest in the arbitral proceeding.
It is thus incumbent to examine the request for reimbursement of the amount unduly paid, increased by indemnity interest.
In the case at issue, it is manifest that, as a result of the illegality of the assessment acts, reimbursement of the tax paid is due, by force of the aforesaid arts. 24, no. 1, paragraph b), of RJAT and 100 of LGT, for this is essential to "restore the situation that would exist if the tax act that is the subject of the arbitral decision had not been performed".
The substantive regime of the right to indemnity interest is regulated in article 43 of LGT, which establishes, insofar as is relevant here, the following:
Article 43
Unduly paid tax obligation
1 – Indemnity interest is due when it is determined, in administrative review or judicial challenge, that there was error attributable to the services from which resulted payment of the tax debt in amount superior to that legally due.
2 – An error attributable to the services is also considered to exist in cases in which, despite the assessment being made on the basis of the taxpayer's declaration, the latter has followed, in its completion, generic guidance of the tax administration, duly published.
The illegality of the administrative review decision is attributable to the Tax Administration, which rejected it on its own initiative.
With respect to the self-assessment, which was effected by the Claimant, it is to be understood that the error affecting it is attributable to the Tax Administration, by the fact that it has been proven that the structure of the Corporate Income Tax Form 22 declaration did not permit the Claimant to effect the self-assessment by deducting the SIFIDE tax benefit from the amount of autonomous taxation rates.
On the other hand, having resulted from the self-assessment tax to be recovered (fields 368 of the declarations of which copies constitute documents nos. 1, 2 and 3, attached with the request for arbitral determination), it should be understood that payment is made as of the date of submission of the first of those declarations, which is 28-05-2012 (document no. 1 referred to) and should have been reimbursed by 31-08-2012, pursuant to article 104, no. 3, of CIRC, in the version then in effect.
Consequently, the Claimant has the right to indemnity interest, pursuant to the provisions of art. 43, no. 1, of LGT and 61 of CPPT from 01-09-2012.
Indemnity interest is due on the amount of € 443,189.22, at the statutory supplementary rate, pursuant to articles 43, nos 1 and 35, no. 10 of LGT, article 24, no. 1, of RJAT, article 61, nos 3 and 4, of CPPT, article 559 of the Civil Code and Regulation no. 291/2003, of 8 April (or any other regulation that alters the statutory rate), from 01-09-2012, until full reimbursement.
- Decision
Accordingly, this Arbitral Tribunal agrees to:
– adjudge the request for arbitral determination to have merit;
– declare the illegality of the ruling of 25-08-2014, of the Head of the Division for Tax Management and Assistance of the Large Taxpayers Unit and annul it in the part in which it rejected the Claimant's claim to deduct SIFIDE tax credit of € 443,189.22 referring to the collection of autonomous taxation rates in Corporate Income Tax;
– declare the illegality of the self-assessment and annul it in the part in which SIFIDE tax credit of € 443,189.22 was not deducted from the collection of autonomous taxation rates in Corporate Income Tax;
– condemn the Tax and Customs Authority to reimburse the Claimant in the amount of € 443,189.22;
– condemn the Tax and Customs Authority to pay the Claimant indemnity interest calculated on the amount of € 443,189.22, from 01-09-2012 and until full reimbursement of the stated amount, at the statutory supplementary rate.
- Value of the case
In accordance with the provisions of art. 305, no. 2, of CPC and 97-A, no. 1, paragraph a), of CPPT and 3, no. 2, of the Regulation of Costs in Tax Arbitration Proceedings, the value of the case is set at € 443,189.22.
- Costs
Pursuant to art. 22, no. 4, of RJAT, the amount of costs is set at € 7,038.00, in accordance with Table I annexed to the Regulation of Costs in Tax Arbitration Proceedings, to be borne by the Tax and Customs Authority.
Lisbon, 08-04-2015
The Arbitrators
(Jorge Lopes de Sousa)
(Paulo Nogueira da Costa)
(Luís Miranda da Rocha)
Frequently Asked Questions
Automatically Created