Professional Documents
Culture Documents
goods to the customer The proceeds from the principles specified at Points 1.1 thru 1.6, Clause
sale is directly paid by company M or by 1, Articice 5, Part B of this Circular due to the
customer M1 to enterprise A. uniqueness and distinctiveness of associated
Comparability analysis: transactions, they shall give the reasons therefor
- Transaction (i) shall be regarded as an and follow the guidance in Article 6, Part B of
this Circular.
uncontrolled transaction of enterprise A;
- Transaction (ii) shall not be regarded as an 2. Comparability analysis and elimination of
differences
uncontrolled transaction of enterprise A because,
though products are delivered from enterprise 2.1. When comparing unitrolled
A's warehouse and sent to custom MI, and transactions selected for compariTtn with
ilk enterprise A and customer MI are not associated associated ones, enterprises shall ayze and
parties, the contract negotiation and signing and assess affecting criteria and adjust material
payment was joined in and controlled by the differences (if any) so as to clarify their4hilarities
parent company. according to the following four critega (below
referred to as four affecting criteria):
1.6. The minimum quantity of uncontrolled
transactions selected for comparison after 2.1.1. Product characteristickininclude
comparability analysis and adjustment of characteristics substantially affecting the product
material differences are made is as follows: price. Factors reflecting product charreteristics
mainly include:
1.6.1. One transaction - in case there is no
difference between an uncontrolled transaction a/ Kind of products (descr ng the
and an associated transaction; or characteristic of product, namely tang e goods,
1.6.2. Three transactions - in case there are copyright, technological know-how ee,service,
differences between an independent transaction etc.) and physical characteristic 6:1 f product
and an associated transaction but enterprises have (component materials, mechanica, physic,
sufficient information and data for eliminating chemical characteristics, etc.);
all material differences; or, b/ Quality and trademark of produt o ;
1.6.3. Four transactions - in case there are c/ Nature of transfer of products (fcCttxample:
differences between an uncontrolled transaction conditional or unconditional purchas s le, such
and an associated transaction but enterprises only as exclusive distribution, licensing, d chising,
have information and data for eliminating most etc.).
material differences. In this case, the further Example 6: Enterprise A, an intit pendent
elimination of other differences must follow the enterprise, produces assorted cotton talc, els (100
guidance on the standard market price range at % cotton), including grade-A cottort4owels of
Point 1.2, Clause 1, Article 5, Part B of this 120 cm x 60 cm size.
Circular. Company M, a Vietnam-based subsidiary
This provision is not compulsorily applicable company with 100% foreign capital, produces
to enterprises which apply the profit split method, assorted cotton towels (100% cotton), including
the first method guided at Item 2.5.2.1, Point 2.5, grade-A cotton towels of 121 cm x 60 cm size
Clause 2, Article 5, Part B of this Circular. for sale (export) to its parent company based in
1.7. In case enterprises cannot select a foreign country.
uncontrolled transactions for comparison on the Assume that other factors reflecting the
but not directly provides the warranty service. It In all cases (with or without written contracts),
has reached an agreement with company A that the bases for identifying contractual terms are
it will pay USD 5 for each cell phone repaired factual events or financial and economic data
by company A during the warranty period. reflecting the character of transactions.
In comparing the associated transaction 2.1.4. Economic conditions of transactions,
(between A and M) and the independent including factors concerning economic
transaction, company A shall conduct conditions on the market at the time of
comparability analysis of the functions between performance of transactions, which affect product
company A and company B and eliminate prices. Economic conditions oftrractions
differences: (below referred to as economic editions)
mainly include: r•t-
- There is a difference between the operational
functions performed by the two companies, a/ The size and geographical poan of the
namely the provision of the warranty service, in product production or sale market;
that company A performs more functions, uses b/ The time and character of tran ctions on
more resources and has a higher profitability the market (for example: normal tan coons of
than company B. wholesale and retail, exclusive di ibution,
- Company A shall adjust the product market segmentation by product consumers);
warranty function by eliminating its actual c/ The competitiveness of produces on the
expenses and revenues connected with the market;
provision of the warranty service. d/ Economic factors affecting proration and
- In case the "warranty" function is business costs incurred at thedlace of
performed just several times with negligible (i.e. transactions (e.g., taxes, chargest—inancial
•
immaterial) expenses and revenues, it is not preferences);
..‘
necessary to adjust this difference.. e/ The State's market regulation tticies.
2.1.3. Contractual terms of transactions, 2.2. The order of priority in co rdacting
covering provisions or binding agreements on comparability analysis of the fou ffecting
the responsibilities and interests of the parties to criteria stated at Items from 2.1.1 to rl .4, Point
&business transactions. Contractual terms of 2.1, Clause 2, Article 4, Part B of thigettrcular is
mirtransactions (below referred to as contractual prescribed for each method .f. price
terms) mainly cover: determination specified in Article 5$1Part B of
a/ The quantity and delivery or distribution this Circular. In the course of analy detailed
conditions of products; analysis is required for priority c ia; for
complementary criteria, analysis not be
b/ The time, conditions and mode of payment;
necessarily detailed but must fully flect the
c/ Conditions of warranty, replacement, basic characteristics of these criteria.
upgrading, repair or adjustment of products;
Example 9: Assume that Vietnamese company
d/ Conditions of exclusive business rights, M (a subsidiary company of international
distribution of products; company M) deals in products X which are of
e/ Other conditions of economic impact (e.g., class-I quality and have been registered in
services of assistance and consultancy on quality Vietnam. In the year 200x, the company managed
control, use instructions, advertisement supports, to select uncontrolled transaction A (between
sales promotion, etc.). Vietnamese company M and an independent
Example 12: Company V, a Vietnam-based 2.2.2. The price at which products are bought
enterprise with 100% capital invested by foreign from an associated party is determined by
company S, is engaged in processing textile and subtracting (-) from the price at which products
garment products. In the year 200x, it had two are sold in the uncontrolled transaction the gross
transactions of processing trousers of cat. 347 profit and other expenses (if any) included in the
as follows: price at which the products are bought (e.g.,
- Transaction I: Processing for parent import tax, customs charge, international
company S 1,000 dozens of trousers at the price insurance and freight).
of USD 60/dozen and delivering the goods at port 2.2.2.1. The gross profit is calculated
X in Vietnam (S will be responsible for exporting according to the gross profit-sellinglrice (net
them). revenue) ratio and the selling price (nevenue),
- Transaction 2: Processing for country N's reflecting the value collected by th=nterprise
company M 1,000 dozens of trousers at the price to offset business expenses and earn al4sonable
of USD 100/dozen and delivering the goods in profit margin.
city Y of country N. The gross profit-selling price (ngrevenue)
Assume that: ratio is the value difference between4e selling
price (net revenue) and the cost r bought
- Company M is not associated with company
products divided by (:) the selling-trice (net
V and company S.
revenue).
- These two transactions are comparable in
2.2.2.2. In case the enterprise peaffms the
transaction conditions, except a material
function of a distribution agent rilving no
difference which is the freight and insurance cost
ownership over products and enjoyinai agency
of USD 3/dozen for the delivery of the goods from
commission expressed as a percentage (%) of
port X to city Yof country N.
the selling price of products, this percetage shall
Comparability analysis:. be regarded as the gross profit-sellin" rice (net
- In comparing transaction 1 (associated revenue) ratio. (See Appendix 2-GC C, not
transaction) with transaction 2 (uncontrolled printed herein).
transaction), it is found that transaction 1 did .
2.2.3. The gross profit-sellingwce (net
F not accurately reflect the market price. Therefore,
company V shall adjust the revenue from the
revenue) ratio of the associated transaction shall
be compared with the most appropriate value
transaction with company S as follows: es based
within the standard range of market
(USD 100 - USD 3) x 1,000 = USD 97,000. on the gross profit ratio for making .yjnstments
- Company V shall declare the processing in compliance with the principles pr-ovided for
charge received from company S being USD at Item 1.2, Clause 1, Article 5, Par4B of this
97,000, instead of USD 60,000. Circular.
2.2. The resale price method 2.2.4. For this method, in making
2.1.1. The resale price method is based on comparability analysis of the four criteria as
the resale price (or selling price) at which guided in Articice 4, Part B of this Circular, the
products are sold by an enterprise to an priority criterion is functions performed by
independent party for determining the price (cost) enterprises and the complementary criteria are
at which these products are bought from the contractual terms, product characteristics and
associated party. economic conditions.
reasonable profit corresponding to the functions profit-cost (cost price) ratio, when comparing the
performed by enterprises and market conditions. uncontrolled transaction with the associated
The gross profit-cost (cost price) ratio shall transaction; or
be the value difference between the net revenue b/ There are differences materially affecting
and cost (cost price) of products divided (:) by the gross profit-cost (cost price) ratio, which
the cost or (cost price). The cost (or cost price) have, however, been eliminated under the
of `products includes direct and indirect guidance in Articice 4, Part B of this Circular.
production expenses but does not include 2.3.6. Factors materially affecting the gross
financial activity expenses (e.g., royalty and loan profit-cost (cost price) ratio normallelude:
interest expenses, etc.). a/ Expenses reflecting the Tthictions
In case an enterprise is unable to separately performed by the enterprise (e.g.00cluction
account the cost (or cost price), sale expenses under contracts, research and development of
and general management expenses, the cost (or new products, the proportion of add alue to
cost price) of products used as a basis for investment or business scope);
calculating the gross profit shall include all of b/ Obligations to perform the co ct (e.g.,
these expenses. time of delivery of products, quality tAntrol and
2.3.2.2. In case an enterprise performs the storage expenses, payment conditions);
function of product purchase agency, having no c/ Accounting methods (ensuni that the
ownership over products and enjoying agency components of the cost (or cost pil) of the
commissions expressed as a percentage (%) of associated and uncontrolled trans ions are
product purchase expenses, this percentage shall
similar or applied with the same ff ounting
be considered the gross profit-cost ratio. (See
standards).
Appendix 2- GCN/CC - not printed herein). •
2.3.7. The cost plus method shalloiiiially
2.3.3. The gross profit-cost (cost price) ratio
apply to the following cases:
of the associated transaction shall be compared
with the most appropriate value falling within a/ Transactions at the stage of laptluction,
the standard range of market prices based on the assembly, manufacture or processing aproducts
gross profit-cost (cost price) ratio for making for sale to associated parties;
tint'
adjustments in compliance with the principles b/ Transactions between associatarties to
prescribed at Point 1.2, Clause 1, Articice 5, Part perform partnership or business coperation
B of this Circular. contracts to produce, assemble, manacture or
2.3.4. For this method, when conducting process products, or agreements on e supply
comparability analysis of the four affecting of input elements for production artfactoring
criteria as guided in Article 4, Part B of this of output products;
Circular, the priority criterion is functions c/ Transactions of provision of services for
performed by enterprises and the complementary associated parties.
criteria are contractual terms, product Example 14: Vietnam-based enterprise A, a
characteristics and economic conditions. subsidiary company of parent company T
2.3.5. The cost plus method shall apply on (country Y), processes shoes for export according
the condition that: to the designs and models assigned by company
a/ There is no difference between transaction T. The parent company is responsible for
conditions which materially affects the gross supplying input materials and auxiliary materials
, t$,
vinHod 1)1031 I? AIIV1 WVN1:31A 0
1.1i spnpoid jo ouez Xlmcpuald atp uo pasNI .ward ad alp 1,1[ d Jo dundwoo kuppisqns Jawouv
aq Hugs por.now aigenduloa ata - T -t7 (Cq panddns s! (smo!wayo 8u!sunap Jawo
pomoul It oid oicreirduloo gun •.t7• puv awq duos) spp,iannu induj •asn moyasnop
.toy' sluahalap saonpatd `,1 inuomnplinut
'000 c9 asn Jo am8g snomaid ivpdno %007 tip (14. dun dwoo rCupp!s qns
aw Jo pnalsw OZ8 '09 agil Jo moo mpn pun
A aspdianta pasnq-ulnulam :c [ aiduivxy
00029 CIO I0 and!j* snomard alp Jo pnalsw
ogeJ (aopd lsoo) isoalijold sso.12 am pm gaud
000`oz asn o anuanat tau dip fo slynq azp uo
X-131 eCnd pun ampap mnis A aS1.1d1a1Ud `Dna laveul aq1 Jo silspq alp uo pauumalap Apuax[r
pios spooX jo aoud uo posrq aspcbaula jo
`09 asn = (sro + r)1000`oz asn uopaesuau paTepossu uE jo sluoulaPlunionui
4S00 11401 alp 8U7JS11.11. 213ag - r# •
(aolid 1S00 JO) lsoo 2u!u!uutaipp-a.1 01
000`oz paildcle aq /Cum poipolu snid lsoo •g -E•
asn = suoi ofr x OOL US!) + 000Zt asn -uoimq SI a o aingff
:071Uattal 19U alp 8111U1Utimap-ad - snot aJd dip fo pnalsw `uoiniq 9Egt,2 (NA Jo
000V7 CirS11 = suol 09 x OOL CIS11 allUattal ainpap Boys y aspdfamit
sl1
:uon.9nsundi pallanuooun azpl in d31.1d -uoppq 9E8- [ chvA4 [ (uoppq
.8U111.9S dy1 01 8U1p.10,90V U011.9VS'Ullp pampossn g- [ + uonnq E[) x ohz] + (tionpq sy+ uopgq
aapl u! adlid &Mpg alp 8u!isn fpnag - £ I) :smonof sv pauwuapp-ai aq l ags SdOlIS
Jo 8u!ssaoald dip wolf anuattad `aS73t111.11 uI
sratouo0 Sn
xnl awooui asudialua fo uoyninoino Jot' SaSUadXd y asydiawa JO suoponsung tmea ars !..indwoo
pun d11Ua eta! s11 ampap [imp A dS1.1d1d1U,7 .tof papaias 8111dg .rod' a1q1211a am tItspdialua
as alp Jo suoponsuati Juaptiadapintayi
'ohc S'1 splaatapp ployasnoti
Supnpaid in pa8v8ua sasudialua Juapuadaptg itso.9 pnol fo ohz pun (asuadra ding. + aSU9C1X,9
fo o!int Iwo mlol-pfald ssod8 ayj - 111aUld2DUVUI dS1.1ddapid + mos spd8 Jo 1S Oa
=) MOO 1D101 JO urns azpl Swag akintp.gutssaoaid
.sao!id 1d)/.1VIU Juapuadapul Jo uosidvdwo.9
Sumpoad pun smnpyt!pul pun suo,„ezniv8.10
Jo potpatu dip diddn ol A dS1.1dialtla Jo•
u8p.mf Jof SaatiS 8U1SS.9.90.1d pun 8u!simpodd osiv
suompuoo 1113 ladW Z pun [ suon.9nsundi
saspdcalua wapuadapu! .1,91110 autos a-Inlay" -
awnssv (owl
413111.1fill11SSV
000'0 (1811 :isod 1v10.1 *U01114 g"1 (NA
00029 USD al11,1d eta( la N - :asuadxa luatua8vuvw .951.1_14w pujvs -
.poyad atp u1 sanag 8111(14.01101 uonpq Er GATA :epos spoo8 pyop
dip pagat spio.9aJ 8u11unoo.9n s dS1.1d.lalUa ala uongq
•1°-1/610Z SI UNA :(.98.mtp 8u!ssaawd) X110411 1, 91V -
asp Jo aoud art!snpxa-IvA dip 173 spvvuuadns St140110f SD Si Sd111411.91)
ysatilop 01 [Nos `SUO1 Op uoyoznirmi - 8111SSadald S'y aS1.10L1d124.9 uo 11011DUL101211 `XXO
-uoyag9 US) Jo ,wart dip tq -spnpardio 8u!ssaoodd alp 111 paunow
aomd gal aup Jr, dr dnal8 Jo dundwoo rCimscins sasuadxa plv Jowl pun spun pnpatd uo pasnq
.1d1pOUV 01 [NOS `S'UO1 09 uoy.9vsundi - saltvzio 8u!ssaowd pled aq fling v aspdtaittg
..Snympu! .9 ouvinsui pun uoyamodsundi muopviudJui
`spooS fo mai 001 Plos A asi-iddalua `x00Z .1 of 8upind pun `s.toloadsul itpmnb pun
(0102 L l kl41/9CZ-t72 sou ope 5u90)
0602 hiNIS0170 sou anssl 3113ZVO TiflOWO Z£
Issue nos 04-05/May 2010 OFFICIAL GAZETTE 33
(Cong Bao nos 234-235/May 17, 2010)
uncontrolled transaction selected for comparison, loan with an interest of USD 100 at the market
serving as a basis for determining the profitability rate.
ratio of products in an associated transaction The ratio of net pre-enterprise income tax
when these transactions have similar transaction profit to net revenue for cars of mark N: 2,000/
conditions. 18,000 x 100% = 11.1%
2.4.2. The profitability ratios are calculated The ratio of net pre-enterprise income tax
by dividing net pre-enterprise income tax profit profit to net revenue for cars of mark S: 1,800/
(income) by net revenue, expenses or assets of 25,000 x 100% = 7.2%
production and business activities according to Assume that material differences been two
the regulations of the regime of accounting and transactions of selling cars of mark Ind mark
financial statements. Net pre-enterprise income S have been adjusted so that the melt of the
tax profit (income) may be added (+) with loan transaction with company Ll achievas•the ratio
interests or fixed asset depreciations for of 11.1% of net profit before enterp income
determining the production and business tax and before payment of interest to revenue.
efficiency before payment of these expenses. In this case, figures on the transactio f selling
Profitability ratios often used include: cars of mark S shall be re-determines cin follows:
2.4.2.1. Ratio of net pre-enterprise income tax Total cost: USD 25,000 - 1,800 - ;00 = USD
income to net revenue from production and
23,100. 1.■
business activities.
Net revenue: USD 23,1001(1- 04 = USD
Example 16: Enterprise L operates in the
25,984.
domain of manufacture and assembly of 4-seat
Net pre-tax and -interest profit: LelP 25,984
cars of marks N and S:
- 23,100 = USD 2,884. eiNg'
comparability analysis of the four affecting profit earned from a combined associated
criteria as guided in Article 4, Part B of this transaction conducted by many associated
Circular, the priority criterion is functions enterprises so as to determine an appropriate
performed by enterprises and the complementary profit of each of such enterprises in such a way
criteria are contractual terms, product that the independent parties share profits in
characteristics and economic conditions. comparable uncontrolled transactions.
2.4.6. The comparable profit method shall be A combined associated transaction
applied on the condition that: participated by many enterprises is a transaction
a/ There is no difference between transaction of unique and distinctive character, cvisting of
conditions which materially affects the many closely interrelated associated 44nsaction
profitability ratio, when comparing the in exclusive products or associated tftsactions
*uncontrolled transaction with the associated conducted between related associate • arties.
transaction; or 2.5.2. The profit split method inrobves two
b/ There are differences materially affecting ways of calculation: =
the profitability ratio, which have, however, been 2.5.2.1. The first way of calc ti on: To
eliminated under the guidance in Article 4, Part allocate the profit to each associated y on the
B of this Circular. basis of contribution of capital (sharing of cost),
2.4.7. Factors materially affecting the by which the profit of each parfkipating
profitability ratio normally include: enterprise (or party) shall be determd on the
a/ Assets, capital and expenses for the basis of allocating the total profit e;Aed from
thee combined associated transaction i1 °portion
performance of main functions of enterprises
to the capital (cost) used in the ociated
(e.g., producing and processing by machines
invested by enterprises may bring about a higher transaction of such enterpriges within the total
profit than producing and processing by investment capital to create end prolucts (see
machines borrowed from other establishments); Appendix 2-GCN/CC, not printed h L.17).
b/ Characteristics of the operation, group of Example 20: -.
products and stage of production or sale (e.g., Vietnam-based enterprise A a . oreign-
finished products made from crude materials or based enterprise B have the mellowing
W'raw materials or from semi-finished products); information:
c/ Accounting methods and structure of - Both are member companies a group T
expenses of products (e.g., products in the period engaged in producing electronic pro an cts.
of rapid depreciation compared to routine - Both participate in producing a nrproduct
depreciation). of LCD televisions.
2.4.8. The comparable profit method is - A is responsible for designing and
considered an extended version of the resale price manufacturing television cabinets and picture
method and the cost plus method. Therefore, the tubes and delivering them to B for assem
comparable profit method is widely applied in other parts (circuits, electronic chip
the cases cited at Items 2.2.7, Point 2.2 and Item invented and manufactured by B. Finished
2.3.7, Clause 2, Articice 5, Part B of this Circular. products will then be sold to C, an independent
2.5. The profit split method distributor, at the price of USD 550 per
2.5.1. The profit split method is based on the - The total cost price per product delivered
...qnsad ssau!snq s‘aslidialua qapa Xq uopousup.p parepossu
pauiguloo dip 1,10 S'd-171g1f aivinaiva-ag - paumwoo am wag puma lgoid onmsal pol alp
pfwd d!svq dip awyg .7 clan (x) 2u!Xidpinul Xq paleinojuo aq upqs aspthalua
go-pa Xq pampa iguld puma' jo uopiod aqi
:poipaul pids )!ford
alp (Cq Lll puv H fo slffaid Supvinaiva fo eCvm -szolouj otos pup anbIun
01 slump lipid 31mi Jo uopiod am 01 uopIppe
OS 0I lgoid II! saspdialua Xq pampa uopaesuan pairpossu
paulquloo am jo lIjoid am sloaTjaz lIjoid
OS 0I lsoo
primal jo uomod silty •uoporsupii pampossp
)uawaRuurm Tulaua2 pup ales
paumwoo alp JO (daps lull am Te pa Xpearre
OS 0£ lsoo cpm lipid DIsrq relol am (-) snmul Jurist pampa
uoponpoid jo lsop - julol alp 'al) lipid runp!sal poi a s 4 pamai
Og I OS
2upptis jo agpluaozad am of 2um, pdsailoo
ON 001 srepawu lndui jo lsop - pgozd'pnmaz jo uou.iod u OAIO/"Ol...10q)111J
:2uqpnioul 'pros spool jo lsoD Hugs uopousue.4 paippossu am TIT 2Ppdppied
(saprpd Jo) saspdialua Jo gorg :11.joca FnmsaT
00g 00Z 011110A0J lON
am atm oj, :daps Pimoos °III 'ZZ .g.Z
IA1 small LA
H •TWIN-fp Slip JO a Ind `g apply `z QSTIRD `iiz
pup c•z 'z-z slupd Te papm2 sr opui Xitkelpoid
000' ctsa :uopmaiva fo pun
JO opeJ Igaid ssoi5 am uo pang sa* ia)putu
':strionof sv an) sauoyd jo auri pnpums atp uppyn anjun iliudoidde
naa guynlapinuvw Jo uopaysunii pappaossv Isom am of 2urpuodsanoo opui yip qpigard
mil 01 palviad yypuv H SdS1.1CLIMIld Jo sanaff alp JO opri lgoid ssoI2 am jo si[ am uo
8upunoaav -siopiqymp Juapuadapu! .91 ales parepiorpo aq um lipid Dtsuqjo uopiod au
iof sauoyd paa apiduro.9 amp advevtifos spaisup ..,
oi..(s1112IJ
puv saigwassv yYaptievi sanquossv sapparfnumu Xpadozd renpanalu! JO slassu ap:p2uptjo asn Jo
H •sauoyd ppaa Suyniovfnuviu dnaa auivs alp dmsJaumo amsnioxa -2-a) siop-ej aios.w anbIun
01 guolaq pi! pm, H sapivdtuo,9 :iz aidwvx-g Jun000p mu! 2uptel lnotpiEm suopo •..rptp jo
•SlOSSU JO sasuadxa Bons 01 aoupupojiad am Tualj aspdialua qap q pampa
aiquolldde saidpupd 2upun000r glim aoumidtuoo uopopsupg paTepossu pouRuloo am =11joJd jo
uI XJ.red goua Xq palm's sasuadxa renpu JO awn am maw.' uopiod silty -suopaarj Ilatp 01
(spinaTID spp uI paqposaid spomatu alp 2uifsn) 2ullmodsanoo lipid oIspq Jo Uo9zoanuoaz
I
saogd laveui jo s!spq aqp uo paurtmalap aq lsnui ireqs uopousurn paTepossu am u! 2 rcippird
slgiz Xliadold fenloallaiui zo slassu am2ur-lu! (sopird Jo) sosptholua Jo low :11joid
jo amen age io pj jonpoid Joj sasuadxg otspq am awls oi :dais Jug NI •- • -z•g.z
-slonpoid :sdals °Au 2upholloj am u! lipid alp areqs
ui 2uppap Io 2upupold Joj pasn slq2p Xpadaid oi :uoprinareo jo kem puooas aqy .z•z•g•z
renioatialuI zo slassu am5uplu! Jo (slunoure 99'990%571 = 00E 1' l0C17:((OSI + 000 - Occ),I
pai-epaidap gupopilqns nip) anjeA iq : s evto n of
lo !cm' ionpaid zoj sasuadxg sv pa/14713Iva s! Ti al paivaollv plaid au
:SiOSSU JO -0c7 QS/1 Si all1P72fillIVIII .1,9111_11ff .101g
sasuadxa 2u!molloj am Jo 2upPqs jo auluaalad ifq paunautiN0.9 alp ampt ooc cisti Sp El al
(otoz 2 d iferuscelcz sou opu 51,9.0)
0 LOZ ABWI90170 sou arms' 3113Z1i9 MOW° 9£
Issue nos 04-05/May 2010 OFFICIAL GAZETTE 37
(Cong Sao nos 234-235/May 17, 2010)