A guide to the taxation of construction and repair works extending over one calendar year

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1 mind that laws are liable to change. All rights are reserved. This booklet may not be quoted (except with adequate citation), copied or reproduced in any form, partially or as a whole, without the prior permission of the author. No responsibility shall be taken for any liability or consequential damages arising from actions taken on the basis of the information contained in this booklet without seeking written professional advice. TURKEY TAXATION OF CONSTRUCTION AND REPAIR WORKS IN TURKEY A guide to the taxation of construction and repair works extending over one calendar year

2 Introduction This booklet was prepared by PricewaterhouseCoopers to provide those planning to engage in construction and repairing activities in Turkey with a broad view of tax and other laws. Please note that the construction activities considered in this booklet refer to those that fall under Public Procurement Law and spanning over more than one calendar year, which are subject to a special taxation regime. However, the taxation principles are applied regardless of whether the work falls under the Public Procurement Law or not. The booklet reflects the current tax law and practices in Turkey as of October This booklet is not intended as a comprehensive or exhaustive study, but merely as an explanatory guide. We would strongly recommend readers to seek professional advice before making any decisions. For further information, please contact the PricewaterhouseCoopers office in Turkey (see Appendix for contact details). October

3 TABLE OF CONTENTS 1. Tax treatment of construction sites 6 2. Types of entities performing construction and repair works 6 3. The provisions for construction and repair works extending 8 over one calendar year 4. The structuring methods of construction work 9 5. The tender process in general Procurement costs The construction commitment process Recording of the transactions related with construction projects (construction related accounts in the Turkish Uniform Chart of Accounts) Allocation of joint general expenses and depreciation expenses The conclusion date of construction and repair works (Temporary acceptance) Expenses and income made after the date of temporary acceptance Taxation principles of construction projects Tax treatment of construction and repair works performed outside Turkey Construction related provisions in other laws Supply of machinery and equipment to be used for construction projects 17 3

4 Glossary Public Procurement Law: The purpose of this law is to establish the principles and procedures to be applied in procurements held by all public entities and institutions governed by public law or under public control or using public funds. Bidder: Real or legal persons or their joint ventures applying for pre-qualification. Contractor: The bidder who is awarded the contract and who signs the contract. Real or legal persons who are responsible for the entire job as a whole. Contracting Entity: Procuring entities and institutions which are within the scope of this Law. Contracting Officer: The authorised personnel or boards of the contracting entity who have competency and responsibility to spend and to initiate procurement proceedings. Subcontractor: Real or legal persons to whom a part of the work is subcontracted by the contractor. Owner: The party of the contract for whom the construction or repair work is performed. Tender security: The guarantee paid by the contractor to the owner, amounting to 3% of the estimated fee (its status is changed to that of final guarantee or it is paid back to the contractor). Performance bond: The guarantee paid by the contractor to the owner amounting to 6% of the agreed fee (it is paid back to the contractor on the date of the final acceptance of the work). Progress payment document: The document stating the cost of the completed part of the work, the withholdings and the net amount payable to the contractor (it must be approved by both the owner and the contractor). Under current legislation, besides progress payment documents, progress invoices must be issued with the same amount. Tender document: With regard to the procurement of goods, services or works that are the subject matter of the tender; the documents including administrative specifications specifying the instructions to tenderers and the project descriptions, together with technical specifications, draft contract and other required documents and information. Preliminary design: In accordance with the final necessity programme of a certain structure, the design consisting of one or more solutions prior to undertaking of 4

5 necessary land and ground studies where the information is obtained from existing maps and the plans, dimensions, outlook and profiles are mentioned as prepared on the basis of the available data including environmental impact assessment and feasibility reports. Final design: In accordance with the approved preliminary design of a certain construction, the design with possible land and ground studies have been undertaken, where the construction elements have been measured and dimensioned, and the construction system, equipment and technical specifications have been indicated. Implementation design: In accordance with approved final design of a certain construction, design indicating any kind of detail of the construction. Procurement: The procedure which involves the award of a contract relating to the purchase of goods, services or works, to one selected tenderer in accordance with the procedures and conditions laid down in this Law, and which is completed with the signing of a contract following the approval of the contracting officer. Tender: An offer, together with the document and/or information submitted by a tenderer to a contracting entity for the procurement carried out pursuant to the provisions of this Law. Contract: Written agreement between the contracting entity and the contractor for the procurement of goods, services or works. Authority: Public Procurement Authority (PPA) Board: Public Procurement Board (PPB) 5

6 1. Tax treatment of construction sites Under the Turkish local legislations, a construction site itself constitutes a permanent establishment regardless of the period of the work. According to Article 7of the tax treaties, relating to the taxation of business profits, the profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise engages in business in the other Contracting State through a permanent establishment situated therein. If the enterprise engages in business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much as is attributable to that permanent establishment. For the purposes of the tax treaties, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried out. The term "permanent establishment" includes: a) a place of management, b) a branch, c) an office, d) a factory, e) a workshop f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. A building site, construction or installation project constitutes a permanent establishment only if it lasts more than a certain period. As mentioned above, a building site itself may be treated as a permanent establishment for tax purposes should the work last more than a certain period. Although the prevailing term is twelve months, bilateral tax treaties can determine it differently (See Appendix I). 2. Types of entities performing construction and repair works Real persons or legal entities resident abroad can only invest in Turkey through joint stock companies, limited liability companies or branches. They may also invest in Turkey by means of participation in a joint venture or ordinary partnership with Turkish companies if they perform construction activities. Even if there are none of these types of entities, a building site itself may be treated as a permanent establishment for tax purposes should the work last more than a certain period of time. 6

7 Set out below is brief information on and a comparison of these forms of investment. Joint Venture (Ordinary Partnership): Does not have a legal personality Bookkeeping requirement in the name of the Ordinary Partnership Is not considered as Corporate Taxpayer Profit or loss is declared by the partners of the partnership in the ratio of their shares Joint Venture (Corporate Taxpayer): Does not have a legal personality Is a type of ordinary partnership Is considered as a full Corporate Taxpayer It is optional to be a Corporate Taxpayer JV The work must be a construction project spanning over one calendar year Bookkeeping, registering, tax declaration and other liabilities are carried out in the name of the JV Consortium: Does not have a legal personality Is a type of ordinary partnership Parties have their own responsibilities for accomplishment of some portion of the whole engagement whilst they may still have joint responsibility for the whole project No declaration and bookkeeping liability in the name of the consortium Profit or loss is declared by the partners of the consortium for their portion of the work Corporate Tax entity (Joint Stock Company, Limited Liability Company): Has its own legal personality Full Corporate Taxpayer Bookkeeping, declaration and other liabilities in the name of the branch Branch: Does not have its own legal personality Limited (Non resident) Corporate Taxpayer Bookkeeping, declaration and other liabilities Permanent Establishment (PE): Does not have its own legal personality Limited Corporate Taxpayer Bookkeeping, declaration and other liabilities in the name of the PE. 7

8 3. The provisions for construction and repair works extending over one calendar year To meet the conditions of Article 42 of Turkish Income Tax Law, which regulates the taxation principles of construction and repair works extending over one calendar year, the project must meet the following requirements: The work to be performed must be construction and repair works, The work must be committed, The work must extend over one calendar year The description of construction and types of construction The academic definition of the term construction Construction includes buildings and their additions, walls, bridges, the supports of a bridge, railroads, railways, fountains, monuments, harbours, water channels, water reservoirs, dams, mining sites, underground storerooms, sewage disposal systems, electricity and telephone pylons, gas pipes, roads, public squares, deep tunnels, shafts etc Definition of the term construction according to the Work Areas Regulation of Ministry of Labour and Social Security Construction is explained as any kind of building works like the structuring of buildings, roads, bridges, tunnels, railways, subways, sewers, ports, wave breakers, pools, fortifications, airports, narrow-gauge railroads, trolley roads, sports fields with their research, project, investigation, repair, maintenance and similar works. In general, construction includes all the activities of the structural part of an immovable that is produced by using equipment and labour work. In Construction Law the term structure refers to the construction of all kinds of fixed and moving, permanent and temporary, official and private, underground and ground structures on land and water with their additions, changes and maintenance Construction works in the form of commitment This means there should be two parties, the owner and the contractor undertaking the work, and the work must be done by the contractor in the owner s name. 8

9 Basically the scope of the commitment contract is as follows: 1. The work to be done, 2. The fee, 3. The termination of the contract, 4. The name and the address of the contractor, 5. The name and the address of the owner, 6. Subcontractors (if any), 7. The means of payments, 8. The amount and the form of the advance payments (if any), 9. Other provisions. In construction works, commitment contracts are considered as exception agreements and are prepared according to Article 355 of the Turkish Law of Obligations. According to Article 355 of the Turkish Law of Obligations, an exception is a contract by which one party undertakes to do something while the other party commits to give something in return Construction and repair works extending over one calendar year The work must extend over one calendar year means the work must not be completed within the same calendar year as it was started. 4. The structuring methods of construction 4.1. Trust method One of the methods for the structuring of construction and repair works directly by the public administration or a responsible committee on behalf of the public administration, without building contractors. The works stated below are performed by the trust method: - In general civil defence and military works - Works whose estimated value is under the value determined annually by the Budget Law - In cases where the public administration has inadequate productive power, machinery and equipment - Works which must be urgently concluded due to risk to lives and property - In cases where the assigned work is left half-done or there are no bidders for the work Bid method The public administration s acceptance of the most suitable proposal of those willing to do that work in order to choose the contractor is known as a bid. In choosing the most appropriate proposal, criteria such as openness, honesty, adequacy, competition, competency, independence and appropriate price are taken into consideration. 9

10 Generally, in diminutions, the appropriate price is the lowest price among the suggested prices and does not exceed the estimated values. However, since the price is not the only criteria, when comparing the proposals, the ones considered as being the most advantageous for the public administration are accepted as the appropriate ones. Therefore, it is possible that in comparisons, the highest price may also be accepted rather than the lowest one when considering the quality of work to be delivered by the building contractor, the machinery and equipment to be used for the project, delivery and operation period, the way of financing the project and other possibilities. The procurement procedures are as follows: Open procedure Restricted procedure Negotiated procedure Direct procurement 5. The tender process in general 5.1. Determination of the estimated cost 5.2. Assignment of a tender commission 5.3. Determination of the procurement procedure to be applied 5.4. Preparation of the record of procurement proceedings 5.5. Preparation of the tender document and the qualification document 5.6. Preparation of the technical specifications 5.7. Procurement announcement 5.8. Submission of the tender document and the qualification document 5.9. Clarifications or amendments to the tender documents Preparation and submission of tenders and submission of applications Payment of tender security (at least 3% of the offered price) Receipt and opening of the tenders and evaluation of the tenders Conclusion and approval of the tender proceedings Tender securities of other participants who are not awarded the contract are returned Notification of finalised tender decisions Performance bond (6% of the contract value) /10,000 of the contract value is paid to the public procurement authority Signing of the contract Notification of the result of the tender 6. Procurement costs 6.1. Tender security Determined by the tenderer in the amount of at least 3% of the offered price. The tender securities are returned afterwards. The accepted values as tender security are as follows: a) Effective Turkish Liras (YTL) in circulation b) Letters of guarantee from banks and special financial institutions c) Domestic Borrowing Bills issued by the Undersecretariat of Treasury and documents 10

11 arranged for replacing these bills 6.2. Performance bond In order to ensure that the commitment is carried out in accordance with the provisions of the contract and specifications, a performance bond calculated as 6% of the contract value, which is returned to the contractor following the final acceptance, is taken. Although neither the tender security nor the performance bond themselves are expense items, they create a financial burden on the contractor Public notary fees More than one real or legal persons can submit tenders by setting up a joint venture. At the tender stage, the joint venture shall be asked to submit an agreement indicating the mutual agreement of the parties to form a joint venture, as well as identifying the pilot partner. Should the contract be awarded to the joint venture, a notary-certified partnership contract shall be submitted prior to signing of the contract. Notary fees are paid as 0.09% of the contract value for each signature but may not exceed the YTL 11, ceiling amount for the year If there is no amount in the agreement, the notary fee will be YTL 3.70 for each signature in the year Providing of tender and pre-qualification documents It is compulsory to buy these documents for tenderers willing to participate in the pre-qualification or tender proceedings. The price of the document shall be determined by the contracting entities provided that it does not exceed its preparation costs and does not impede competition PPA s share Prior to signing the contract, 0.05% of the contract value is paid to the public procurement authority if the contract value exceeds YTL 165, Stamp duty If the contract includes a certain amount, the stamp duty is levied as 0.75% of the amount stated in the agreement. However, stamp duty to be paid may not exceed YTL 800,000.00, the ceiling amount for the year However, under the Turkish tax regulations, certain incentives exist for some special projects, so stamp duties and notary fees may not be payable Other general and administrative expenses such as the cost of feasibility works 7. The construction commitment process The commitment process may be summarised as follows: 6.1. Procurement procedures 11

12 6.2. Signing the contract 6.3. Performing the work by the contractor 6.4. Temporary acceptance 6.5. Final acceptance 8. Recording of the transactions related with construction projects (construction related accounts in the Turkish Uniform Chart of Accounts) According to the General Communiqué of the Uniform Chart of Accounts Number 2, account groups 17 and 35 are assigned for the use of construction works. According to this communiqué, costs of constructions extending over one calendar year are followed cumulatively in the accounts No Advances given to the subcontractors are followed up in the account number 179. The amount of progress invoices of construction and repair work extending over one calendar year is followed in accounts number Expenses incurred within the year are followed in the account No 740 and at the end of the year transferred to the accounts No At the end of the work, the accumulated costs of construction in accounts No are transferred to the account No 622 Cost of Services Rendered. Progress invoices issued during the work-in-progress are recorded as credit to accounts and are transferred to the account No 600 within the accounting period in which the project is completed. Moreover, according to the General Communiqué of the Uniform Chart of Accounts Number 12, accounts 178, 358 and 697 are assigned for the use of inflation adjustments. The differences of accounts and occurred from inflation adjustments are followed in the account number 697 and according to the balance of that account those differences are transferred to account No 178 or 358. At the end of the work, they are transferred to the account No 648 or Allocation of joint general expenses and depreciation expenses The term joint expenses in construction and repair works refers to a situation where there is more than one construction and repair works or other activities together with construction and repair works. The main aim of the provisions in the Turkish Income Tax Law is to allocate the expenses appropriately and calculate the profit and loss of each project correctly. However, some expenses such as general and administrative expenses may not be distributed among the specific works. If it can be determined that expenses of a joint general nature can be matched with works or projects, then these can be directly allocated to the related works or projects. According to Article 43 of the Turkish Income Tax Law which states the fundamentals of allocation of joint general expenses; 12

13 1- If more than one construction and repair works extending over one calendar year are carried out together, joint expenses for each year are allocated among the works in the ratio of the costs of each work to the total project costs of the related year. The relevant cost is the inflation adjusted cost. Example Total Cost (inflation adjusted value) : 250 Inflation adjusted cost of Project A : 100 Inflation adjusted cost of Project B : 150 Joint Expenditure : 50 The Portion of Project A: 100 = 100 x 50 = The Portion of Project B: 150 = 150 x 50 = In cases where in the same year one or more construction works are conducted together with works which are not of the nature defined in this article, the joint general expenses of each year are allocated in the ratio of the costs of each construction work and the revenue of other works to the total of the direct construction costs and the revenue of the other works. The relevant costs are the inflation adjusted values. Works Ratio Joint Expenses A-Inflation Adjusted Project Cost B-Inflation Adjusted Project Cost C-Revenue from Other trading activities 500 Total Joint expenses to be allocated 100 The principles of allocation of depreciation expenses Depreciation of the facilities, machinery and transportation vehicles that are used in more than one construction and repair works or together with other works are allocated on the basis of the number of days in which they are used for each works. In cases where such a determination could not be made, then depreciations should be allocated in the same way as joint general expenses. 13

14 10. The conclusion date of construction and repair works (temporary acceptance) Article 44 of the Income Tax Law states the ending date of construction and repair works so that in cases where construction work is conducted on the basis of temporary and final acceptance, the date on which the minutes of temporary acceptance are approved by the administration is accepted as the date of conclusion; in other cases, the conclusion date means the date on which the work is actually completed or is actually abandoned. 11. The treatment of expenses and income made after the date of temporary acceptance Any kind of expenses made and revenues generated following the conclusion date related to such a project is taken into account in the determination of the profits or losses of the year in which the expenses are made or the revenues are generated. 12. Taxation of construction and repair works 1. Withholding tax 2. Corporate income tax 3. Dividend taxation 4. VAT 5. Stamp duty Withholding tax (taxation of project-in-progress) According to Article 94/3 of the Income Tax Law, both work advances and progress invoice amounts paid to those performing the work, i.e. contractors or subcontractors, are subject to withholding tax at a rate of 5%; - Even if the construction contract states that the duration will not extend over one calendar year, should the work actually extend over a calendar year, then the payments corresponding to the extended period are subject to withholding tax. - Withholdings can only be deducted from the tax calculated on the final profit from the related work. - Should there still be an amount of tax which could not be deducted from the tax calculated on the profit of the project due to insufficient income, the excess advance tax amount can be refunded or deducted from other taxes payable on condition that all the requirements of tax laws are met Corporate income tax (final taxation) In construction and repair projects extending over one calendar year, the final determination of the profit and losses shall be made only in the year in which the project ends. The income calculated in the year in which the temporary acceptance is made is taxed under the legislation of the same year. The corporate tax rate is 30%. 14

15 Enterprises must file corporate tax returns until April 15 th of the following year and pay the tax promptly until the end of the month in which filing is made. The prescription period of 5 years starts one year from the date of the temporary acceptance Dividend taxation In construction projects extending over one calendar year, final determination of the profit and losses shall be made only in the year in which the project ends; profit from the project is distributed afterwards. Under the current regulations in Turkey, dividend withholding tax rate is 10% if dividend is distributed to non-residents and resident individuals. Dividend distributions to resident corporations are exempt from withholding tax. However, the bilateral tax treaties, which may determine lower tax rates, should also be considered Value Added Tax (VAT) Under the Turkish VAT Law, rendering services in Turkey is subject to VAT. Therefore, contractors are liable for VAT on progress invoices at a rate of 18%. Please note that advance payments are not subject to VAT unless an invoice is issued. The VAT liability occurs on the date of the acceptance of progress payment by the owner. The contractor may credit the VAT incurred on purchase of goods and services against the output VAT on the supply of goods and services provided by it and pay the difference due. If the amount of credit exceeds the amount charged by the contractor, the excess credit is carried forward. In order to claim the credit, the invoice or similar documents must include the VAT separately for each item and they must be recorded in the enterprise s legal books. However, it is not necessary that the VAT should actually have been paid, i.e. VAT liability and deductibility is computed on an accrual basis. Taxable base The taxable base of a transaction is generally the total value of the consideration received not including the VAT itself. In progress payments, while the bid discount and the accumulated progress payments previously paid are deducted, withholding taxes are included in the VAT base. In addition, advance payments, guarantees, late payment penalties and such other withholdings are not deducted from the tax base. Payment of VAT The tax mechanism operates on the basis of tax returns filed by taxable entities within the period indicated in the VAT Law. It is currently applied as the 26th day of the following month. 15

16 VAT withholding According to the latest amendments in the Turkish VAT regulations, the owner is liable to withhold 1/3 of the VAT (18%*1/3= 6%) on the construction services amounts and pay directly to the related tax office under the so-called reverse charge mechanism if the owner comes under one of the following descriptions: Departments with general budget, administrations with supplementary budget, special provincial administrations, municipalities and their unions, Foundations with circulating capital, Public corporations and institutions established under special laws, Public body like professional institutions Universities, except for those established by foundations, Retirement funds and benevolent funds having legal personality established under special laws, Banks and private financial institutions, Public economic enterprises, Companies in the privatisation portfolio, Organised industrial zones and all exchanges including stock exchange and futures market, Corporations with a minimum of 51% public ownership belonging to institutions and enterprises listed above (alone or together). Firms whose shares are quoted on the Istanbul Stock Exchange It is also true that in such circumstances where the owner is one of the institutions listed above, the contractors are also liable to withhold 1/3 of the VAT (18%*1/3= 6%) from the subcontractors on the construction services amounts Stamp duty According to the Stamp Tax Law, both advance payment receipts and progress invoices are subject to Stamp duty at a rate of 0.75% on the amount indicated in the document. In advance payments, the taxable base is the advance payment amount. On the other hand, there is more than one amount in the progress payment documents and the taxable base is the amount of payment for the work performed within the related period. Stamp duty is withheld from the progress payments and paid to the tax office by the owner. 13. Tax treatment of construction and repair works performed outside Turkey Profits from construction and repair work and technical services performed outside Turkey, which are added to the income generated in Turkey, are exempt from corporate tax regardless of whether such profits are transferred to Turkey or not. On the other hand, should these kinds of profits be distributed to the shareholders, they are taxed as dividends. However, if the distributed profits are from the years before 2003, they are not subject to dividend taxation as previously they were subject to withholding tax regardless 16

17 of whether they were distributed before the date April 24 th, Construction related provisions in other laws Labour Law According to Article 36 of the Turkish Labour Law, public administrations and owners of construction and repair works are liable for payment of the wages and salaries which are not paid to the workers employed by the contractors or the subcontractors by means of withholding them from the progress payments. The wages and salaries are deducted from the progress payments and paid directly to the workers after some necessary checks by the owners Social Security Law Public administrations and owners of construction and repair works are liable for the payment of social security withholdings from the wages and salaries of the workers employed by the contractors or the subcontractors by means of withholding them from the progress payments. The social security liability amount is withheld from the contractors receivables (progress invoices) and paid by the owner directly to the related Social Security Management. 15. Supply of machinery and equipment to be used for construction projects Domestic purchase Recorded as expense by means of depreciation Domestic financial leasing Recorded as expense by means of depreciation; interest payments are directly recorded as expense Domestic ordinary leasing The leasing payments are directly recorded as expense Permanent importation Recorded as expense by means of depreciation Temporary importation Recorded as expense by means of depreciation if the contractor has the ownership of the machinery and equipment Overseas financial leasing Recorded as expense by means of depreciation and interest payments are directly recorded as expense. The lessee is liable to withhold income tax at the rate of 1 %. 17

18 Additionally, the leasing payments are subject to VAT at the rate of 1% or 18% (the rate differs depending on whether the lessor is a financial leasing company or not.) under the socalled reverse charge mechanism on the grounds that the services have been benefited from in Turkey in connection with the activities of the lessee. The lessee has to calculate and pay the VAT to the related tax office on behalf of the lessor. However, the lessee is allowed to treat the VAT paid as input VAT in the same month and is able to offset the same against output VAT, if any Overseas ordinary leasing The leasing payments are directly recorded as expense. The lessee is liable to withhold income tax at the rate of 22%. Additionally, the leasing payments are subject to VAT at the rate of 18% under the so-called reverse charge mechanism on the grounds that the services have been benefited from in Turkey in connection with the activities of the lessee. The lessee has to calculate and pay the VAT to the related tax office on behalf of the lessor. However, the lessee is allowed to treat the VAT paid as input VAT in the same month and is able to offset the same against output VAT, if any. Investment incentives The purchase of machinery and equipment is exempt from VAT and other taxes paid at customs if the contractor holds an investment incentive certificate. Besides, according to the Turkish Income Tax Law, 40% of the cost of the machinery is deducted from the corporate tax base should all the requirements determined by the law be met. 18

19 Appendix I According to the tax treaties between Turkey and the following countries, a construction site itself is treated as a permanent establishment if it lasts more than the following periods: Minimum period The bilateral tax treaty between Turkey and; (Month) 1 Germany 6 2 USA 6 3 Albania 12 4 Austria 6 5 Azerbaijan 12 6 Belgium 6 7 White Russia 12 8 United Arab Emirates 12 9 Bulgaria Algeria 6 11 People s Republic of China Denmark 6 13 Indonesia 6 14 Finland 6 15 France 6 16 South Korea 6 17 Croatia India 6 19 The Netherlands 6 20 United Kingdom 6 21 Israel Sweden 6 23 Italy 6 24 Japan 6 25 Kazakhstan Kyrgyzstan Kuwait 9 28 Turkish Republic of Northern Cyprus 6 29 Lithuania 9 30 Hungary Macedonia Malaysia 9 33 Egypt 9 34 Mongolia 24 19

20 35 Moldova Norway 6 37 Uzbekistan Pakistan 6 39 Poland Romania 6 41 Russia Singapore 6 43 Republic of Slovakia Tajikistan Tunisia 6 46 Turkmenistan Ukraine Jordan 6 49 Syrian Arabian Republic 9 50 Spain 6 51 Greece Slovenia Latvia 9 54 Bangladesh Sudan The Czech Republic Thailand Luxembourg 6 59 Estonia 9 60 Iran 6 20

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