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On January 29, 2020, the National Constituent Assembly ("ANC") approved through a Decree the partial reform of the Decree with Rank, Value and Force of Law of the Organic Tax Code published in the Official Gazette No. 6.152 Ext. of November 18, 2014 ("Code of 2014"). The Decree of reform ("Code of 2020") was published in the Official Gazette No. 6.057 Ext. of January 29, 2020. We believe the Code of 2020 is clearly unconstitutional, but we will assume the authorities will apply it, as the Supreme Court of Justice has authorized through several decisions the application of other laws and decisions of the ANC.

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