The agenda

• The opening statement of the forum

• Introduction to the forum
• Presentation of tax topics
• The presentation explains some of the procedures for
registering tax agents and tax agencies
• Answer inquiries
• Closing word

1
The opening statement

His Excellency General Manager Khaled Al Bustani

2
• Introduction to the forum

Mr. Obaid Aman

Head of the services sector of the government sector and major companies

3
tax topics

Mrs. Saeda Kaddoumi Othman

Senior tax policy expert

4
Topics

Zero application of goods and services

Input tax segmentation

Settlement of Disputes

5
Zero application of goods and services

6
 Zero application of goods and services

Education services

Health care
services Zero
application
of goods and
services

Export goods

Export services

7
 Health care services

It is provided by an entity,
health care institution, doctor,
nurse, etc. Licensed by the
Ministry of Health or by
another competent authority.
02 It is generally recognized
within the medical
profession as necessary for
the treatment of supply
recipients.
01
Any medications or medical
equipment specified in Council
of Ministers No. (56) of 2017. 04 It must be linked to human
health.
03
‫ من الالئحة التنفيذية‬41 ‫*المادة‬

8
Health care services - practical considerations

• Medical services in the luxury suites are unnecessary to treat the supply.
• These services do not meet the conditions under which they are subject to
Medical services
•
zero.
These services do not meet the requirements for a single combined supply and
are therefore subject to VAT.
provided in luxury
suites
01
• In order to apply a zero rate, the service must be provided for the purposes of
treating the recipient.
Health care services
• Health care services from business to business are subject to VAT. from business to
business 02
• Registering with the Ministry of Health and Community Protection is not Medicines / medical

03
sufficient to apply the zero rate to the import or supplyof medicines / medical
equipment; equipment registered with
• Medicines / medical equipment must also meet the definition specified in the Ministry of Health and
Cabinet Resolution No. (56) of 2017.
Community Protection

• Medical examination services are not related to employee treatment and

do not prevent any medical condition / disease that may arise in the
Medical examinations
•
future;
Services are provided under a contractual agreement to the employer and
not to the recipient of the supply.
before employment 04

9
 Education services

The curriculum must be

recognized by the federal or
local government regulating
the education sector.
02 The supplier must be
licensed by the federal or
local government regulating
the education sector.
01
04 03
Only the goods and services In the higher education
provided by recognized sector, the educational
educational institutions to institution must be owned
associate persons with those by the federal or local
institutions are subject to zero. government or have
obtained more than 50% of
its annual funding from the
government.
* Article 40 of the executive regulations

10
Education services - practical considerations

• The federal or local government regulating the education sector Professional training

01
does not recognize the institution or the curriculum;
provided by companies
• Vocational training is subject to 5% value added tax.
to specialists

• It is not treated as a supply of education services under paragraph

(a) of item (4) of Article (40) of the executive regulations, as the Entry / application
•
recipient is not considered an affiliate of the educational institution.
Subject to 5% value added tax.
fee before affiliation 02
• The zero rate is applied only when the field trip is fully linked to the
Field trips organized
03
curriculum and is not primarily entertaining.
• The educational institution must be able to demonstrate that the
field trip is related to the curriculum.
by educational
institutions

• This fee is deemed to be a “security / deposit” and not subject to A refundable security
•
supply.
However, if the fee is deducted as a consideration for the supply of a
good or service, then such supply may be subject to VAT.
deposit when the
child leaves school 04

11
Export goods
02
Indirect export
The buyer / external customer is
responsible for receiving the goods from
the supplier, exporting them outside the
country, or placing them in a suspended
status of customs duties within 90 days
from the date of supply.
04
VAT is payable in the event that the
goods are not exported within 90 days or
a longer period that the Federal Tax
Authority has approved.
01
Direct export
The goods are actually exported by the
supplier or his agent outside the
country, or they are placed in a
suspended status of customs duties
within 90 days of the date of supply.
03
Submit an official and commercial
proof of export.
* Article 30 of the executive regulations
12
Export goods - practical considerations

• The goods exit certificate shall be the only official document proving the
Official proof of export
01
export of goods outside the country.
• The customs declaration is not sufficient to prove the export of the
goods.

• If the transport of goods is related to two or more basic transactions, only Transfer of goods

•
the last transaction is subject to zero-tax.
As for the previous sales transactions, they are subject to 5% value added
tax.
associated with multiple
transactions 02
• The Federal Tax Authority may allow the supplier to apply a zero rate to Indirect export: lack of
the indirect export of goods with an alternative evidence that proves the commercial evidence

•
export after reviewing all facts and circumstances related to this
transaction.
Prior approval must be obtained from the Federal Tax Authority in this
proving that the external
customer exports the
03
regard. goods in his possession

• The supplier must issue a credit memo to the zero taxable previous tax
invoice and also issue a taxable tax invoice at the base rate under which Indirect export: The

•
VAT is charged to the supply.
This is done on the assumption that the customer did not export the
goods within 90 days of the date of supply.
customer
submitted
has not
export
documents within 90 days
04

13
Export services
02
The recipient of the service must be outside
the country when providing services.
04
The service must not be received by
another person in the country who is not
able to fully recover the input tax.
01
Recipients of services must not have
a place of residence in the country.
03
The services must not be supplied in
direct connection with real estate or
commodities present in the country
at the time the services are
provided.
* Article 31 of the executive regulations
14
Export services - practical considerations

• Personal movable assets include all the goods in the country. Meaning and scope of
• When performing service in relation to a commodity present in the
country, then the zero rate is not applied.
use of the term
"personal
assets"
movable 01
• Marketing services may be subject to zero tax if the recipient is not Marketing /
resident and is outside the country when providing services.
• The fact that marketing services are fully provided in the country does not
prevent the application of the zero rate to those services.
promotional services
provided
country
in the 02
• The zero rate applies only in cases where the place of supply is the United
Arab Emirates (the country). The services are
• provided completely
03
If the place of supply is outside the country, the supply is considered to be
outside the scope of the VAT, and it is not subject to zero tax.
• For performance-based services such as repair of goods, the place of
outside the country,
supply is the place where the services are performed. but the recipient is
resident in the country

15
Input tax segmentation

16
Fractionation of input tax - basic principles

Is it no
related to No
business? refund

yes yes
yes

To make fully
To make mixed To make fully
taxable supplies
supplies exempt supplies

No
Full Input tax
refund
recovery segmentation

17
 Input tax segmentation - the basic mechanism

Tax is not Full Input Tax

refunded (0%)
Input tax Refund (100%) • Every tax period.
segmentation

b c a • Recalculation of
percentage and
recoverable input
tax at the end of
the tax year
(wash-up).
𝑎
X% = c:
(𝑏+𝑎)

Note: Clauses 6 to 10 of Article 55 of the Executive Regulations of Decree-Law as well as Section 2.3 of the Input 18
Tax Fractionation Manual contain more details in this regard.
 Alternative
Input Tax Segmentation - Alternative Mechanisms

Alternative
fragmentation
mechanisms

A mechanism
Business division Space-based based on the Output - based
mechanism mechanism number of mechanism
transactions

• The basic mechanism of segmentation may not be appropriate in all cases.

• The authority permits the application of a number of alternative mechanisms for

dividing the input tax, which reflects the actual use of goods and services if it deems
that the alternative mechanism is more just.

19
Select "Actual Use" - options available
This mechanism can be used by: Output-based mechanism ‫م‬
1. Insurance companies (Islamic and non-Islamic)
2. Retail banks (Islamic and non-Islamic) 𝑇𝑎𝑥𝑎𝑏𝑙𝑒 𝑠𝑢𝑝𝑝𝑙𝑖𝑒𝑠
3. Banks that provide banking services to major X% =
companies / institutions and investment banks (Islamic
and non-Islamic)
𝑇𝑜𝑡𝑎𝑙 𝑠𝑢𝑝𝑝𝑙𝑖𝑒𝑠
(𝑆𝑢𝑝𝑝𝑙𝑖𝑒𝑠 𝑓𝑜𝑟 𝑛𝑜𝑛−𝑏𝑢𝑠𝑖𝑛𝑒𝑠𝑠 𝑝𝑢𝑟𝑝𝑜𝑠𝑒𝑠 + 𝑒𝑥𝑒𝑚𝑝𝑡 + 𝑡𝑎𝑥𝑎𝑏𝑙𝑒 ) 1
4. Transportation Service Providers

This mechanism can be used by: The mechanism is based on the number of transactions ‫م‬

1. Money exchange offices

𝑇ℎ𝑒 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑡𝑎𝑥𝑎𝑏𝑙𝑒 𝑡𝑟𝑎𝑛𝑠𝑎𝑐𝑡𝑖𝑜𝑛𝑠
2. Banks that provide banking services to major X% =
companies / institutions and investment banks that
carry out trading activities (Islamic and non-Islamic)
𝑇𝑜𝑡𝑎𝑙 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑡𝑟𝑎𝑛𝑠𝑎𝑐𝑡𝑖𝑜𝑛𝑠
(𝐹𝑜𝑟 𝑛𝑜𝑛−𝑏𝑢𝑠𝑖𝑛𝑒𝑠𝑠 𝑝𝑢𝑟𝑝𝑜𝑠𝑒𝑠 + 𝑒𝑥𝑒𝑚𝑝𝑡 + 𝑡𝑎𝑥𝑎𝑏𝑙𝑒 ) 2
This mechanism can be used by: Space-based mechanism ‫م‬
1. The real estate sector, such as those that sell and
rent commercial and residential properties.
𝑇ℎ𝑒 𝑎𝑟𝑒𝑎 𝑢𝑠𝑒𝑑 𝑓𝑜𝑟 𝑡𝑎𝑥𝑎𝑏𝑙𝑒 𝑎𝑐𝑡𝑖𝑣𝑖𝑡𝑖𝑒𝑠
2. Other businesses that sell and rent real estate on X% =
an ongoing basis (ex: educational and medical
institutions that provide housing to students /
𝑇𝑜𝑡𝑎𝑙 𝑎𝑟𝑒𝑎
3
employees).

Item 3 of the Input Tax segmentation guide

20
Select "Actual Use" - options available
Business division mechanism ‫م‬

the bank

• Mechanism of the
number of employees
• Output mechanism
4
Stock trading
insurance (Based on the segmantation
real estates
(Based on the number of (Based on the
(Based on area)
output) transactions or output)
outputs)

The mechanism is expected to be used by corporations and large companies / tax groups, banks and insurance companies
that operate its operations through different divisions and departments - for example: banks have different divisions such
as retail and bank investments; or insurance companies that offer life insurance contracts and other insurance contracts .

Section 3.4 of the Input Tax Fragmentation Manual 21

Division-based allocation mechanism - number of
employees
About the mechanism
The numbering mechanism is used when the
overheads incurred are closely related to the
number of employees as a result of the expenditures
that these employees consume. For example, for
insurance companies that offer long and short term
insurance contracts, the company's employees are
divided between these two divisions.
Mechanism users
This mechanism is suitable for a wide range of
companies involved in providing services, as the
company's overheads are related to the people who
work for it.
the background
This mechanism uses the number of employees
appointed or employed in each department / sector
(who generate revenue without those working in
supporting departments). Typically, staff numbers are
measured on a full-time basis.
Mathematical formula
(100/1) X The number of employees in the
sector / section
Total number of employees
 Business division allocation mechanism - output

About the mechanism the background

This mechanism is preferred if costs (excluding non- The value of income in the sector can be a reflection of the input
taxable costs such as staff costs) are related to income tax incurred on costs, as in successful businesses where there is
and this could have been done in a fairly consistent usually an association between costs and income.
manner in all departments / departments. However, it may
be inappropriate if some departments / departments are in
the construction phase and other departments /
departments are in the usual operating phase.

Mechanism users
This mechanism can be applied to different types by
different institutions, including private and non-profit
Mathematical formula
sectors.

(100/1)
The value of supplies in the sector
X Total value of supplies / supplies
for non-business purposes
Fragmentation of input tax - practical considerations

• Prior permission must be obtained in order to use the special mechanisms for
dividing the input tax.
• The taxpayer must submit the accounts of the alternative mechanism and the
primary mechanism of the Authority in order to issue its decision in this
regard.
Obtain prior permission to
use a special mechanism 01
• If the taxable person uses the basic mechanism of segmentation, he is
expected to make the following two amendments:
• a. Make adjustments based on the percentage and amount recalculated at

•
•
the end of the year
B. Make adjustments based on actual use
If an alternative hash mechanism is adopted, adjustments are only required
Annual accounting procedures
02
based on recalculation of the ratio and amount at the end of the year

• The supply consists of two components, namely, taxable supply (imposed

fee) and exempt supply (realized profit margin).
•

03
In the event that there are two different components in the same supply,
which is therefore subject to different tax transactions, this is considered as Money exchange offices - the
two transactions instead of one. mechanism based on the
number of transactions

24
 Input tax segmentation - common errors
2. The basic mechanism
Input VAT excluded from recovery from the primary
mechanism accounts.
3. Output-based mechanism
Expenditures that are subject to the reverse charge
mechanism must be excluded from the output-based
mechanism’s accounts, as they are considered inputs, not
outputs.
4. A mechanism based on the number of
transactions
Input-related transactions (including expense associated
with the reverse charge mechanism) should be excluded
when performing the number-of-transaction mechanism
calculations.
5. Space-based mechanism
Common common areas such as lounges and elevators
should be excluded when calculating the business space
available for commercial or residential use.
1. General guidelines
• Submit a stamped / signed letter by the authorized
signatory.
• Submit the calculations of the basic mechanism and
the proposed alternative mechanism in "Excel" format
for the period of twelve (12) months prior to submitting
the application. Calculations must be made for each
tax period separately, as well as for standard
calculations for the 12-month period.
• Ensure that the recovery ratio is rounded to the
nearest whole number.
• Clarify in the accounts whether the expenditures are
fully earmarked for exempt supplies or taxable
supplies or if all expenses are residual expenses.
• Please ensure that there are no differences between
the accounts that are submitted as part of the
application and the tax returns. If there are any
differences, they must be clearly explained.
25
Input tax segmentation - common errors

6. Mechanism of dividing the business into departments / sectors

a. Customizations:
• Presenting the used mechanism on which the remaining input tax was allocated in the various
departments / sectors
• If the number of employees mechanism is the approved allocation mechanism, provide a detailed
statement of the total number of employees, which must indicate the total staff working in the head office
and the supporting management office in addition to any employees who are contracted, even if not all of
these employees are included in the mechanism accounts Number of Employees.
B. Sections / sectors:
• Please provide detailed information on the activities of each section / sector.
• Please include the retail mechanisms used for each department / sector as well as the reasons for using
this mechanism.
• Please provide the accounts that show how the recovery rate is calculated for each department / sector.

26
Settlement of disputes

27
 Dispute Resolution Options
In the event that the taxable person finds that the authority’s decision does not comply with the provisions of
tax legislation, he may appeal this decision. The authority provides three levels for settling tax disputes, the
arrangement of which is progressive, as follows:

Appeal before the Tax Dispute

competent court Resolution reconsidering
Committee

Note: A reconsideration request is submitted by the person to the commission to reconsider its decision in respect
of it in whole or in part, provided that the request is justified.

28
Reconsideration requests
• Any person may submit a request to the Commission
to reconsider any decision issued on it, provided that
the request is reasoned, within 20 working days from
the date of notification of the decision.

• The commission must study the reconsideration

request that meets the conditions and decide on it
within 20 working days from the date of receiving the
application.

• The Commission shall inform the applicant of its

decision within 5 working days from the date of the
decision.

• The reconsideration form can be found under the item

"electronic forms" on the Authority's website.

• If the taxable person is not satisfied with the results of

the review, he may object to the decision within 20
working days.

29
Reconsideration request - required documents
• As part of a reconsideration request, the person must
provide the following documents:

 The decision issued by the commission to which the request

for review is related;

 An official letter including details of the facts and legal

references, the applicant’s technical view and the alternative
tax treatment that the applicant believes can be applied;

 Any other supporting documents to support the factual and

legal reasons on which the reconsideration request is
submitted (for example: invoice forms, contracts, payment
vouchers, etc.).

30
Reconsideration request - fines
• Submitting a reconsideration request does not result in stopping the imposition of daily fines if the
amount of the tax due has not been paid.

• It is not within the authority of the commission to stop imposing fines as they are imposed under a text
of the law and that the commission is the body responsible for implementing and enforcing legal and
legislative provisions.

• In all cases, the taxable person must pay any tax due to cease the imposition of daily fines or other
periodic fines before submitting a reconsideration request.

• However, the Commission has a measure of discretionary power to reduce and / or exempt from fines
in specific cases and this will be considered in the context of review - as mentioned in Article (46) of
Federal Law No. (7) of 2017 regarding tax procedures and Article (26) of Cabinet Resolution No. (36) of
2017 regarding the executive regulations of Federal Law No. (7) of 2017 regarding tax procedures.

• In such cases, it should be clearly indicated in the person’s request that the request relates to the terms
and conditions of Article (46) of Federal Law No. (7) of 2017 regarding tax procedures.

• The Authority is currently studying the preparation of a separate application that is used specifically to
submit applications related to the reduction or exemption of fines.

31
Reconsideration request - fines
• And Article (46) of Federal Law No. (7) of 2017 regarding tax procedures indicates that there are conditions
and controls that must be met to reduce or exempt from administrative fines, Article (26) of the executive
regulations of the same law stipulates these controls and conditions as follows:

 That the person have an excuse acceptable to the commission.

 The person submits the evidence that justifies the existence of the excuse and the violation thereof, which led
to the imposition of administrative fines.

 Notify the commission of a request to reduce or waive according to the mechanism it determines, within 10
working days of the removal of the acceptable excuse.

 The person is not subject to any administrative fines in the two years prior to submitting the application.

 The person proves that he has corrected his violation.

32
Tax Dispute Resolution Committee

• The Tax Dispute Resolution Committee (the Committee) comes in the second phase of the dispute settlement
process. If the person remains dissatisfied with the commission’s decision regarding his reconsideration
request, the person may object to this decision before the Tax Dispute Resolution Committee through the
Ministry of Justice.
• The committee is considered an independent entity from the Federal Tax Authority and is formed under the
chairmanship of a member of the judiciary and two tax experts.
• There are currently three committees in the emirate of Abu Dhabi, Dubai and Sharjah, where the Tax Dispute
Resolution Committee in the Emirate of Abu Dhabi and Dubai is competent to consider applications submitted
by taxpayers residing in the emirate, while the Tax Dispute Resolution Committee in the Emirate of Sharjah is
competent to consider applications submitted by taxpayers residing in all Northern Emirates (i.e. Emirate of
Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah and Fujairah).
• The Tax Dispute Resolution Committee is specialized in the following:
1. Decide on objections submitted to the decisions of the commission regarding requests for review.
2. Deciding on the reconsideration requests that were submitted to the Authority and which did not take a decision
in accordance with the provisions of the relevant law.

33
Tax Dispute Resolution Committee
• In order to challenge the commission’s decision regarding the reconsideration request, the objection must be
submitted to the Tax Dispute Resolution Committee (the commission) within 20 working days of the date of
notification of the commission’s decision.

• The objection submitted to the committee shall not be accepted in the following cases:
1. If a request for review is not submitted to the Authority initially; or
2. If the objected tax and fines are not paid.

• The committee will study and challenge the objection within 20 working days. Noting that the committee may
extend the period for deciding the objection for a period not to exceed 20 additional working days if it considers
reasonable reasons for the purposes of deciding the objection.

• The committee’s decision is final if the total tax due and disputed administrative fines does not exceed 100,000
dirhams.

34
Appeal before the competent court
• In cases where the sum of the tax due and the disputed administrative fines
exceeds 100,000 dirhams, the authority or person may appeal the committee’s
decision before the competent court within 20 working days from the date of
notification of the decision.

• The appeal shall be before the competent court in the following two cases:
1. Objection to the committee’s decision in whole or in part; or
2. No decision was issued by the committee regarding an objection submitted to it.

• The court is the supreme authority with regard to tax appeals, so the court's
decision is final.

35
Clarifications on some procedures
for registering tax agents and tax
agencies
Salman Musharbak
Tax registration official
Registration of tax agents and tax agencies

36
 Introduction - The difference between the approval and
registration of the tax agent in the registry
Obtaining
Registration the tax Pay the
Connecting
in the tax agent's registration Pass the Initial
with a tax
agents approval fee tests approval
agency
register number
TAAN

332
A tax agent
122
An agent hasen't
454
Certified tax agent
registered in the connected yet
registry (I.e. they are not
registered in the
register and they
must do so to carry
out their business)
The data is on December 8, 2019

37
 How to link with a tax agency and be registered in the
tax agents register
‫الحصول على‬
Obtaining the
‫القيد في سجل‬in
Enrollment Connecting
‫رقم اعتماد‬
tax agent's ‫رسوم‬ ‫دفع‬
Pay the
Pass‫اجتياز‬
‫ الوكالء‬of
the register with a tax the tests ‫ية‬‫المبدئ‬approval
Initial ‫الموافقة‬
tax ‫الوكيل الضريبي‬
approval ‫ التسجيل‬fee
registration ‫االختبارات‬
‫الضريبيون‬
agents agency
number
TAAN

The tax agent can complete the link with a tax agency in two ways

The second way The first way

Register a facility as a new tax agency and complete the Connecting with one of the tax agencies registered with the
link in the same application for registration of a tax agency authority

The facility submits an

application for In the event that the tax 3 2 1
registration of a tax agent is: The agency submits The agent shall
agency through the Owner the request to link to The agent agrees with communicate with one
electronic services partner the authority through the agency to link of the agencies
system Employee the electronic services appearing on the
At a facility eligible to register system Authority's website
as a tax agency with the
Taxes
Authority
Accounting
and Auditing
Legal advice

38
 Clarification on the link between the agent and the
agency
A single tax agency can have more than A tax agent cannot connect to more
one tax agency associated with it than one tax agency at the same time

39
 Transactions between the parties concerned
The correct way for a tax agent to represent The general way of dealing between
the taxable person before the authority the taxable and the authority

‫الخدمات اإللكترونية‬
e-services

40
 Incorrect actions that the tax agent may take to
represent the taxable

Definition of a tax agent with a tax agent Taxable representation without Take the username and password of the
approval number for himself as a interconnection via the electronic system taxable account
registered agent without being associated
with a tax agency

Taxable representation through the Authority's electronic services system

41
 Adjusting the records of the tax agent
Adjusting the linkage with tax agencies Modify the contact information
Examples

E-mail
An action taken by either
party directly through the Phone / mobile number
electronic services system Title

Username for electronic services

 The amendment feature is not

available in the e-services
The official website
system E-service dashboard
 The authority should be of the authority
consulted because
modification of the linkage
leads to "suspension" of the
agent and agency records
The authority shall communicate with the two parties with
reference to the official documents (such as residence and
work card) in the event of a dispute

42
 Mechanism for submitting requests to amend the
records of tax agents and tax agencies

 Currently there is no feature for amending tax agents and tax agency records
automatically (i.e. via the e-services system)

 However, amendment requests can be submitted in the following way:

Send a scanned copy of the Fill out the amendment form with
Authority's amendment form by e- the supporting documents
mail

43
Cancellation of tax agent registration

The Authority will cancel the tax agent’s registration by removing its data from the tax agents record, in
case the agent does not voluntarily want to continue his role as a tax agent

Cancellation of registration is different from "striking off the agent from the registry", where the deletion
is the result of an action taken by the commission based on the performance criteria of tax agents

The prepaid tax agent registration fee of AED 3000 is considered. Not refundable even if the agent does
not complete the full 3-year registration period

Anyone wishing to cancel the registration must contact the authority to submit a request to cancel the
registration

44
 Channels of communication with the authority for tax agents

Tax clarifications and review The body in general Tax Agents Support Team Registration Division

For an official answer to purely For all inquiries. The general (For the tax agent transactions (For transactions related to tax
technical matters related to tax communication channel for all associated with the taxpayer he agent and tax agency
laws and to submit tax the Authority's customers represents) registrations only)
reconsideration requests

www.tax.gov.ae www.tax.gov.ae
taxagentaccoun
Fill out a form
t@tax.gov.ae

taxagents@tax.gov.ae

600 599 994

In Arabic only In both Arabic or English

45
Mechanism for receiving requests
from the tax clinic for tax agents
Registration Department

46
 Tax clinic for tax agents
To answer inquiries and process outstanding tax agent requests and transactions related only to

Register the taxable persons represented by the tax

Registration of tax agents and tax agencies
agent
 VAT registration  Connectivity
 Selective tax registration  Edit records
 etc.  Notes

Review the Wait for the Request a

registration ticket number ticket
officer to be called

47
Conclusion word

48
We thank you for coming

49