Stamp Tax on Land for Construction: Verba 28 TGIS Housing Classification Ruling

ARBITRAL DECISION

I. REPORT

1. The company A…, S.A. (hereinafter referred to as the "Claimant"), with tax identification number …, with registered office at …, …-…, …, municipality of …, submitted, pursuant to the combined provisions of articles 2 and 10 of Decree-Law No. 10/2011, of 20 January, i.e., the Legal Framework for Arbitration in Tax Matters ("LFATM"), a request for the constitution of an Arbitral Tribunal in order to declare illegal the assessment of Stamp Tax ("ST"), relating to the fiscal year 2013, in the amount of €3,676.37, regarding an urban property, legally classified as land for construction, registered under article …, in the urban property register of the parish of …, of the municipality of ..., with the Tax and Customs Authority ("Respondent" or "TCA") being sued.

A) Constitution of the Arbitral Tribunal

1. Pursuant to the provisions of subparagraph a) of paragraph 2 of article 6 and subparagraph b) of paragraph 1 of article 11 of the LFATM, the Ethics Council of the Administrative Arbitration Center ("CAAC") appointed the undersigned as arbitrator of the single-arbitrator tribunal, who communicated acceptance of the assignment within the applicable period, and notified the parties of this appointment on 10 February 2015.

2. Thus, in accordance with the provision of subparagraph c) of paragraph 1 of article 11 of the LFATM, and through communication from the President of the Ethics Council of the CAAC, the Single Arbitral Tribunal was constituted on 24 March 2015.

B) Procedural History

1. In the request for arbitral decision, the Claimant petitioned for the declaration of illegality of the ST assessment mentioned above, with reference to an urban property located at …, in the parish of … and registered in the urban property register of that parish under article ….

2. The TCA presented its response, petitioning for the dismissal of the request for arbitral decision, as there was no breach of law, requesting that the tax act under analysis, as it did not violate any legal or constitutional provision, be maintained in the legal order.

3. The Tribunal was duly constituted and is competent to examine the issues indicated (article 2, paragraph 1, subparagraph a) of the LFATM); the parties have legal personality and capacity and have full standing (articles 4 and 10, paragraph 2 of the LFATM and article 1 of Ordinance No. 112-A/2011, of 22 March). No nullities have occurred and no exceptions have been raised, and therefore nothing prevents judgment on the merits.

4. The present case is thus in a position for the final decision to be rendered.

II. QUESTION TO BE DECIDED

1. The central question to be examined and decided regarding the merits of the case, as emerges from the procedural documents of the parties, is whether urban properties legally classified as land for construction should be covered by the concept of properties with residential use, pursuant to Entry No. 28 of the General Table of Stamp Tax ("GTST").

2. That is, the present tribunal seeks to determine whether, as the Claimant alleges, land for construction is not classified as properties with residential use, thereby falling outside the scope of the aforementioned entry, or, conversely, as the Respondent contends, they are considered properties with residential use and, in this context, subject to ST, pursuant to Entry No. 28 of the GTST.

III. FACTUAL FINDINGS AND THEIR JUSTIFICATION

1. Having examined the documentary evidence produced, the present tribunal finds the following facts proven as relevant to the decision of the case:

I. The Claimant is a co-owner of an urban property (holds 26% thereof), legally classified as land for construction, registered under article …, in the urban property register of the parish of …, of the municipality of ..., with a Taxable Patrimonial Value ("TPV") of €1,413,990.

II. The Claimant, regarding the fiscal year 2013 and as a result of Entry No. 28 of the GTST, received the assessment notice from the TCA, relating to the first installment (No. 2014 …), in the amount of €1,225.47, of a total amount of €3,676.37 (of the ST assessment relating to that fiscal year).

III. As the Claimant did not agree with that assessment, it filed a request for administrative review, which was denied.

IV. On 28 May 2014, the now Claimant constituted a voluntary mortgage on the property in question, with the objective of dealing with an anticipated fiscal enforcement proceeding (regarding the assessment previously mentioned), and incurred €495 in connection with the mortgage constitution.

V. Since the TCA did not accept that real guarantee, the Claimant paid the 1st installment of the assessment mentioned above, on 18 September 2014, with accruals, in a total amount of €1,278.05.

1. The present tribunal's conviction regarding the facts found as proven resulted from the documents annexed to the case file and contained in the petition and uncontested allegations of the parties, as specified in the points of the factual matter set forth above.

2. There is no factual matter relevant to the decision of the case found as not proven.

IV. ON THE LAW

A) Legal Framework

1. Given that the legal question to be decided in the present case requires the interpretation of the relevant legal texts, it is important, first, to set out the provisions that compose the relevant legal framework, as of the date of occurrence of the facts.

2. The subjection to ST of properties with residential use resulted from the addition of Entry No. 28 to the GTST, carried out by article 4 of Law 55-A/2012, of 29 October, which defined the following tax events:

"28 – Ownership, usufruct or right of surface of urban properties whose taxable patrimonial value recorded in the register, in accordance with the Municipal Property Tax Code (MPTC), is equal to or greater than €1,000,000.00 – on the taxable patrimonial value used for purposes of municipal property tax:

28.1 – For property with residential use – 1%

28.2 – For property, when the taxpayers that are not natural persons are residents in a country, territory or region subject to a tax regime clearly more favourable, included in the list approved by ordinance of the Minister of Finance – 7.5%".

1. The aforementioned law also added, to the Stamp Tax Code, paragraph 7 of article 23, relating to the assessment of ST: "in the case of tax due for the situations provided for in entry no. 28 of the General Table, the tax is assessed annually, in relation to each urban property, by the central services of the Tax and Customs Authority, applying, with the necessary adaptations, the rules contained in the MPTC", and article 67, paragraph 2, which provides that "to matters not regulated in the present Code relating to entry 28 of the General Table, the MPTC shall apply subsidiarily".

2. In this context, and having regard to the above indication, let us turn our attention now to the Municipal Property Tax Code ("MPTC").

3. In the MPTC, the types of properties are enumerated (in articles 2 to 6), as follows:

"Article 2 – Concept of Property

1 – For the purposes of the present Code, property is any portion of territory, including water, plantings, buildings and constructions of any nature incorporated therein or situated thereon, with a permanent character, provided that it forms part of the patrimony of a natural or legal person and, under normal circumstances, has economic value, as well as water, plantings, buildings or constructions, under the circumstances above, endowed with economic autonomy in relation to the land where they are located, although situated in a portion of territory that constitutes an integral part of a diversely owned patrimony or does not have patrimonial nature.

2 – Buildings or constructions, although moveable by nature, are deemed to have a permanent character when affixed to non-transitory purposes.

3 – The permanent character is presumed when the buildings or constructions are situated in the same location for a period exceeding one year.

4 – For purposes of this tax, each autonomous fraction, under horizontal property regime, is deemed to constitute a property.

Article 3 – Rural Properties

1 – Rural properties are lands situated outside an urban agglomeration that are not to be classified as land for construction, in accordance with paragraph 3 of article 6, provided that:

a) They are affixed to or, in the absence of concrete affixture, have as their normal purpose a use generating agricultural income, as these are considered for purposes of personal income tax (PIT);

b) Not having the affixture indicated in the preceding subparagraph, they are not built upon or have only buildings or constructions of an accessory character, without economic autonomy and of reduced value.

2 – Rural properties are also lands situated within an urban agglomeration, provided that, by virtue of a legally approved provision, they cannot have a use generating any income or can only have a use generating agricultural income and are in fact being used for this purpose.

3 – Also rural properties are:

a) Buildings and constructions directly affixed to the production of agricultural income, when situated on the lands referred to in the preceding paragraphs;

b) Water and plantings in the situations referred to in paragraph 1 of article 2.

4 – For purposes of the present Code, urban agglomerations are considered, in addition to those situated within legally fixed perimeters, clusters with a minimum of 10 dwellings served by public roadways, with their perimeter delimited by points distanced 50 m from the axis of the roadways, in the transversal direction, and 20 m from the last building, in the direction of the roadways.

Article 4 – Urban Properties

Urban properties are all those that should not be classified as rural, without prejudice to the provisions of the following article.

Article 5 – Mixed Properties

1 – Whenever a property has rural and urban parts, it is classified, in its entirety, in accordance with the main part.

2 – If neither of the parts can be classified as main, the property is deemed to be mixed.

Article 6 – Types of Urban Properties

1 – Urban properties are divided into:

a) Residential;

b) Commercial, industrial or for services;

c) Land for construction;

d) Other.

2 – Residential, commercial, industrial or for services are buildings or constructions licensed for such purposes or, in the absence of a license, that have as their normal purpose each of these uses.

3 – Land for construction is considered to be land situated within or outside an urban agglomeration for which a license or authorization has been granted, prior notification admitted or favorable prior information issued for subdivision or construction operation, and also land that has been so declared in the acquisition title, except land where the competent entities prohibit any of those operations, namely those located in green zones, protected areas or that, in accordance with municipal land use plans, are affixed to public spaces, infrastructure or equipment.

4 – Included in the provision of subparagraph d) of paragraph 1 are lands situated within an urban agglomeration that are not land for construction nor are covered by the provision of paragraph 2 of article 3, and also buildings and constructions licensed or, in the absence of a license, that have as their normal purpose purposes other than those referred to in paragraph 2, and also those in the exception of paragraph 3".

1. In parallel, and since it is one of the issues raised by the Respondent, it is necessary to highlight the provision in article 45 of the MPTC Code.

"Article 45 – Taxable Patrimonial Value of Land for Construction

1 - The taxable patrimonial value of land for construction is the sum of the value of the building implantation area, which is that situated within the perimeter of the building's fixation to the ground, measured by the exterior part, added to the value of the land adjacent to the implantation.

2 - The value of the implantation area varies between 15% and 45% of the value of the authorized or planned buildings.

3 - In establishing the percentage of the value of the implantation land, the characteristics referred to in paragraph 3 of article 42 are taken into consideration.

4 - The value of the area adjacent to the construction is calculated pursuant to paragraph 4 of article 40.

5 - When the document evidencing constructive viability referred to in article 37 only makes reference to the land use plan indices, the assessing experts must reasonably estimate the respective construction area, taking into account, in particular, the average construction areas of the surrounding area".

1. Finally, attention must also be paid to the rules on the interpretation of laws, which are fundamental for understanding the scope of the concept of property with residential use.

2. Article 11 of the General Tax Law ("GTL") establishes the essential rules for interpretation of tax laws as follows:

"Article 11 – Interpretation

1. In determining the meaning of tax provisions and in qualifying the facts to which they apply, the general rules and principles of interpretation and application of laws are observed.

2. Whenever tax provisions employ terms specific to other branches of law, they must be interpreted in the same sense as they have therein, unless otherwise directly provided by law.

3. If doubt persists regarding the meaning of the applicable provisions on taxable events, the economic substance of the tax facts must be considered.

4. Gaps resulting from tax provisions covered by the legislative reservation of the National Assembly are not susceptible to analogical integration".

5. The general principles of interpretation of laws, to which paragraph 1 of article 11 of the GTL refers, are set forth in article 9 of the Civil Code, which establishes the following:

"Article 9 – Interpretation of Law

1. Interpretation should not limit itself to the letter of the law, but should reconstruct from the texts the legislative intent, taking especially into account the unity of the legal system, the circumstances in which the law was drafted, and the specific conditions of the time in which it is applied.

2. However, the interpreter cannot consider legislative intent that does not have in the letter of the law a minimum of verbal correspondence, even if imperfectly expressed.

3. In establishing the meaning and scope of the law, the interpreter will presume that the legislator adopted the most appropriate solutions and knew how to express his intent in adequate terms".

4. Thus, it is within the present legal framework that it is important to decide whether urban properties classified as land for construction are, or are not, included in the concept of property with residential use, pursuant to Entry No. 28 of the GTST.

B) Arguments of the Parties

1. In this regard, the Claimant argued, in summary, as follows:

2. "Land for construction is not included in the provision of the rule contained in entries 28 and 28.1 of the GTST (…), as it does not have residential use".

3. Since, for this party, article 6, paragraph 2 of the MPTC Code, which defines the concept of residential properties, "…points to the need for an actual, real and present use. Therefore, the fact that a given piece of land for construction is authorized for the construction of a property destined for housing does not determine any change in the classification of the land which, for tax purposes, continues to be considered as such".

4. In this sense, the Claimant considers that, from the MPTC Code, there is a clear distinction between urban properties "residential" and "land for construction", and the latter cannot, for purposes of ST, be classified as properties with "residential use".

5. The now Claimant also supports its argument in case law already produced on the subject, namely in some arbitral decisions already rendered, which will be analyzed in greater detail below, where it has been stated peremptorily that land for construction cannot be considered urban properties with residential use.

6. The Claimant further emphasizes that this understanding is only changed with reference to the fiscal year 2014 and thereafter, with the modification of the wording of the relevant provision to "for residential property or for land for construction whose building, authorized or planned, is for residential purposes…" (emphasis ours).

7. In parallel, the Claimant draws attention to the fact that it is only a 26% owner of the urban property in question, considering, as such, that its patrimony amounts only to €367,637.40 and not to €1,413,990, and, since it was "…the legislator's objective to tax those with above-average tax capacity, for which it considered the value of one million, if there were no other reason – which by mere hypothesis we will admit, but we do not conceive – this prerequisite fails".

8. In other words, in the Claimant's understanding, there would only be incidence of ST if the share it holds had a TPV exceeding one million euros. Since this is not the case, the Claimant considers that "there is a violation of the principles of legality, fiscal equality, and the prevalence of economic substance over formal legal reality".

9. The Claimant also considers that the application of the aforementioned entry to properties built and held for sale by construction companies is doubly unjust, since "in the first place the construction sector is the only sector of activity that is effectively taxed for the possession of its inventories, and in the second place, because when it is taxed, the value considered for application of the tax is not the effective cost of production, ascertained and recorded in the company's accounts, but rather the TPV determined for tax purposes, which, as a rule, is higher than that".

10. The now Claimant is also of the opinion that Entry No. 28 of the GTST is unconstitutional for violating the constitutional principles of legality, justice, equality, and impartiality.

11. Finally, the Claimant draws attention to the fact that it constituted, on 28 May, a voluntary mortgage on the property in question with the purpose of dealing with the anticipated fiscal enforcement proceeding on assessment No. 2014 …, and that the same (mortgage) was not accepted by the TCA as a real guarantee, since, on the date of its constitution, the said proceeding had not yet been initiated.

12. In this sense, the Claimant considers that, in accordance with the provision of paragraph 2 of article 169 of the Code of Tax Procedure and Process, once the period for voluntary payment of the aforementioned assessment has expired, a guarantee provided before the filing of an administrative review, judicial claim or judicial appeal is sufficient to also suspend enforcement, provided that a petition is filed containing the nature of the debt, the period to which it relates, and the entity that performed the act, as well as the intention to file a means of action for the discussion of the legality or exigibility of the debt being enforced.

13. The Claimant ended its submission by requesting that:

A) The present request for arbitral decision be judged procedurally well-founded and, consequently, the assessment in question be annulled, or declared null (with the legal consequences, namely annulment of the fiscal enforcement proceeding instituted).

B) Entry No. 28.1 of the GTST be considered unconstitutional when viewed as "a taxation of ownership of properties with residential use of value exceeding 1 million euros in cases where it is merely the exercise of its economic activity in violation of the constitutional principles of legality, justice, equality, and impartiality".

C) The Claimant be granted the right to an indemnity in the amount of €1,773.50, plus party costs that may be due, for undue guarantee; and

D) The request for cancellation of the Voluntary Mortgage, constituted in accordance with this proceeding, be judged procedurally well-founded.

1. The Claimant also arranged for one witness to be called, B….

2. For its part, the Respondent, after being duly notified to do so, presented its response in which, in summary, it alleged as follows:

3. "In the absence of any definition of the concepts of urban property, land for construction and residential use, in the ST provisions, one must resort to the MPTC, in search of a definition that permits determining any subjection to ST, in accordance with the provision of article 67, paragraph 2 of the ST Code in the wording given by Law No. 55-A/2012, of 29/10".

4. Establishing that, pursuant to the aforementioned legal provision, to matters not provided for in the ST Code, and relating to Entry No. 28 of the GTST, the provision of the MPTC Code must be applied, in a subsidiary manner.

5. The Respondent then develops an extensive rationale that, in its opinion, permits classifying land for construction in the concept of property with residential use, supporting itself, in particular on article 45 of the MPTC Code.

6. "As results from the expression '…value of authorized buildings', contained in article 45, paragraph 2 of the MPTC Code, the legislator chose to determine the application of the property valuation methodology in general, to the valuation of land for construction, and therefore they are applicable the use coefficient provided for in article 41 of the MPTC Code".

7. The Respondent therefore understands that, if for purposes of determining the TPV of land for construction there is an application of the use coefficient (in the valuation of the land), then that coefficient should also be considered, for purposes of applying Entry No. 28 of the GTST.

8. Additionally, in the opinion of the Respondent, "the mere constitution of a right of construction potential immediately increases the value of the property in question, hence the rule contained in article 45 of the MPTC Code that requires separating the two parts of the land.

On one side, the part of the land where the building to be constructed will be located is considered, and on the other the area of free land (…)."

1. Therefore, for the Respondent, "well before the actual construction of the property, it is possible to determine and establish the use of the land for construction".

2. The Respondent concludes that, based on the above, "the assessment at issue constitutes a correct interpretation and application of the law to the facts, does not suffer from a breach of law (…) and should, consequently, the claim be judged without merit and the Respondent be absolved of the petition".

3. With regard to the request for witness testimony produced by the Claimant, for the Respondent there is no need for production of additional evidence (i.e., beyond the documents already attached to the case file).

4. Considering thus that "there is no need for witness testimony to be heard given that the tribunal can and must officially know of all legal questions raised, without the need to first hear the witnesses called".

5. In conclusion, the Respondent requests that the petition for declaration of illegality and consequent annulment of the contested assessment be judged without merit, thereby absolving the same of the petition.

C) Tribunal's Assessment

1. In the opinion of the present tribunal, and having regard to the legal framework previously presented, the essential normative proposition to be considered for the decision of the case is that which results from Entry No. 28 of the GTST.

2. It is also noted that, in the eyes of the Arbitral Tribunal, the question to be decided concerns exclusively a matter of law, namely to understand, for purposes of applying the aforementioned entry, whether the concept of property with residential use includes, or does not include, land for construction.

3. To this end, the present tribunal will closely follow Arbitral Decision relating to case No. 42/2013-T, of 18 October (a decision which, from the outset, it commends for its relevance, detail, and proximity to the present discussion (also mentioned by the Claimant)).

4. By way of introduction, it should be noted that the MPTC Code does not resort, in the classification of urban properties, to the concept of property with residential use (in fact, this concept is also not found in any other statute).

5. Thus, it is necessary to conduct, based on the legal framework set forth above, an interpretation of the concept of property with residential use.

6. In this regard, and in order to support the present decision, we transcribe below part of Arbitral Decision No. 42/2013-T, of 18 October, where the following was decided:

"From a literal interpretation of the provision on taxable events in question, it appears that the legislator wished to include within the scope of application of the provision urban properties that have a 'residential use'.

The expression 'residential use' does not appear to be able to have any meaning other than residential use, that is, urban properties that have an actual use for residential purposes, either because they are licensed for such, or because they have this as their normal purpose.

And we cannot confuse an 'actual residential use' which implies an actual affixture of an urban property to that end, with the expectation, or potentiality, of an urban property being able to have a 'residential use'.

Land for construction, not being built, do not satisfy, by themselves, any condition to be considered as properties with residential use, since, on the one hand, they do not have use licenses for housing, and, on the other hand, they are not habitable (because they are simply not built).

Therefore, it does not seem to us sufficient to be classifiable in the objective provision on taxable events in question that there exists the expectation of an urban property being able to have a residential use, or having the potentiality to have a residential use" (emphasis ours).

1. Now, in the case of land for construction, in fact, there exists nothing more than the mere expectation, (or, possibly, potentiality), of the same, and only after construction, to have a residential use.

2. However, only when the aforementioned use is realized, can we consider that the urban property falls within the scope of Entry No. 28 of the GTST.

3. In fact, the concept of residential use must undoubtedly be traced back to something that is capable of being inhabited, even if, as mentioned above, it is not legally recognized as such.

4. As such, notwithstanding that land for construction will likely result in the future in a property with residential use, while it remains as such (that is, legally classified as land for construction), it cannot, as of the date of the facts, in the opinion of the present tribunal, be included within the scope of application of Entry No. 28 of the GTST.

5. In parallel, the TCA demonstrated, as described above, that, in its opinion, it is by virtue of article 45 of the MPTC Code, that land for construction is classified as properties with residential use.

6. In this context, and for its relevance to the present decision, let us turn our attention once more to Arbitral Decision No. 42/2013-T, of 18 October.

7. As stated in the aforementioned arbitral decision, "article 45 of the MPTC Code is intended for the valuation of land for construction, considering as one of its elements the authorized or possible purpose, in light of urban planning constraints.

Once again we are only in the field of potentialities, of expectations, and this is not sufficient to alter the nature of the property, which continues to be considered as land for construction, nor to support that the property in question comes to have a 'residential use' for purposes of the objective provision on taxable events of entry 28.1 of the GTST".

1. Thus, it is the opinion of the present tribunal that, as of the date of the facts, the concept of property with residential use, referred to in Entry No. 28 of the GTST, is traced exclusively to the concept of residential urban property, in accordance with article 6, paragraph 1, subparagraph a) of the MPTC Code.

2. In other words, in the opinion of the present tribunal, in accord with the opinion expressed by the Claimant and in Decision No. 42/2013-T, of 18 October, the TCA cannot resort to article 45 of the MPTC Code to establish a relationship between land for construction and property with residential use.

3. In that sense, the present tribunal concludes that, since the urban property in question is land for construction, it cannot be included within the scope of Entry No. 28 of the GTST.

4. In parallel, and notwithstanding that the framework established so far is, from the perspective of the present tribunal, sufficient to recognize the illegality of the assessment act performed by the TCA, it is important to note that, if there were doubts, the recent amendment to the text of Entry No. 28 of the GTST would certainly dispel them.

5. In fact, Law No. 83-C/2013, of 31 December, which came into force on 1 January 2014, amended the text of entry no. 28 of the GTST to "residential property or land for construction whose building, authorized or planned, is for residential purposes, in accordance with the provisions of the MPTC Code (…)" (emphasis ours).

6. Now, in the opinion of the present tribunal, such amendment occurred, naturally, because the legislator will have perceived that there was a need, verified only from 2014 onwards, to extend the aforementioned entry to land for construction, in the manner referred to above.

7. In these terms, it is clear that until that date (2014), the text of the entry previously mentioned left out of its scope of application properties legally classified as land for construction (otherwise, there would have been no need to amend the text of the aforementioned entry).

8. Thus, and based on the reasons set out above, the present tribunal understands that land for construction cannot, as of the date of the facts, be covered by the concept of property with residential use, as referred to in the text of Entry No. 28 of the GTST, and therefore concludes that the legal premise for taxable incidence does not exist.

9. Finally, it is noted that, with respect to the remaining arguments presented by the Claimant, namely the issue of co-ownership, the present tribunal refrains from examining them, as it considers that the understanding set forth above is sufficient to clarify the matter under discussion.

10. Additionally, with regard to the production of additional evidence, as requested by the Claimant, namely the calling of witnesses, the present tribunal understands that this is not necessary, particularly, and as mentioned by the TCA, given that we are dealing with a strictly legal question.

V. DECISION

1. For these reasons, this Arbitral Tribunal decides:

A) To judge the petition for arbitral decision well-founded and, consequently, to declare illegal and annul the ST assessment mentioned above, relating to 2013, which resulted in tax payable in the amount of €3,676.37, relating to the taxation of urban properties with residential use, pursuant to the provision of Entry No. 28 of the GTST;

B) To condemn the Respondent to reimburse the Claimant for the amount paid by it during the course of the proceeding, as set out above, in the total amount of €1,773.05 (€1,278.05 relating to the assessment and €495 relating to the expenses of the mortgage constitution), plus compensatory interest;

C) To judge the petition for cancellation of the Voluntary Mortgage provided in the course of the present proceeding as well-founded;

D) To condemn the Respondent in the costs of the proceeding.

VI. VALUE OF THE PROCEEDING

1. The value of the proceeding is fixed at €4,223.95, pursuant to article 97-A, paragraph 1, subparagraph a) of the Code of Tax Procedure and Process, applicable by virtue of subparagraphs a) and b) of paragraph 1 of article 29 of the LFATM and of paragraph 2 of article 3 of the Regulation of Costs in Tax Arbitration Proceedings ("RCTAP").

VII. COSTS

1. In accordance with the provision of article 22, paragraph 4, of the LFATM, the value of the arbitration fee is fixed at €612, pursuant to Table I of the mentioned Regulation, charged to the Respondent, given the full merit of the petition.

Notify.

Lisbon, CAAC, 15 July 2015

The Arbitrator

(Sérgio Santos Pereira)