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Chapter: 5 Who Is a Non-Resident Taxable Person under UAE Corporate Tax? — Transcript

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0:00Welcome back to chapter 5. In chapter
0:03four, we discussed about uh resident uh
0:07jurorical person and resident natural
0:09person. Now in chapter 5, we are going
0:12to discuss about non-residents.
0:15When a non-resident will be subject to
0:18corporate tax in UAE and uh on what
0:21basis they will pay taxes and when is
0:23their registration deadline and what is
0:26their obligation in corporate tax. This
0:27is what we are going to discuss.
0:30Now non-resident similar same like
0:34resident I'm bifocating into
0:38two which is jurorical person
0:42and uh natural person.
0:47When it comes to jurorical person when a
0:50jurorical person will be subject to
0:53corporate tax if that person is a
0:54non-resident. Non-resident is like you
0:57know someone who is uh a foreign company
0:59you can make it very simple it's a
1:02foreign company when a foreign company
1:04will be subject to UAE corporate tax
1:07this is what we are going to discuss
1:10there are three situation a jurorical
1:12person will be subject to corporate tax
1:14in UAE first one if the foreign company
1:20has a permanent
1:23establishment in 2A
1:30in short form we can call it PE.
1:33Second one if a foreign company has a
1:37nexus
1:38in UAE.
1:41Third scenario if a foreign uh company
1:46has any source income
1:50from UAE.
1:54These are the three situation when a
1:57non-resident a foreign company will be
2:00subject to corporate tax in UAE where it
2:02is explained in corporate tax law. It is
2:05explained in corporate tax law again
2:06article 11.
2:11Now we are going to discuss what is
2:14permanent establishment, what is nexus,
2:16what is source income.
2:19Before that for resident any resident
2:23person like they are going to pay taxes
2:26in UAE on their worldwide income.
2:31We discussed this in the previous
2:33chapter where it is explained they are
2:36going to pay taxes on worldwide income.
2:38Article 12 of UA corporate tax law. In
2:41the same article, article 12, it is
2:44explained that if a person is a
2:46non-resident, if a person is a
2:48non-resident, they are not going to tax
2:51on the worldwide income. Instead, that
2:54foreign company will be paying taxes on
2:57the income
3:00generated from UAE.
3:06If a foreign company is generating any
3:08income from UAE, UAE will tax only in so
3:12far that income is attributable to UAE,
3:16not only worldwide income.
3:19When
3:21an income which is attributable to UAE
3:24will be sub.
3:31So means
3:34the foreign company if they have PE or
3:37nexus or source income whatever income
3:39they're generating from those PE or
3:42nexus or the income from source that
3:44will be subject to UA corporate tax.
3:50Now what is permanent establishment?
3:52Permanent establishment means
3:55in simple form you can you can say it's
3:58a presence
4:00in the country.
4:03How a foreign company can have presence
4:06in in in UAE? Either they can have a
4:09fixed place in UAE
4:13or they can have
4:15people in UAE.
4:19In technical term it's it's called fixed
4:21place PE and agency PE. We will discuss
4:23this. If a foreign company a UK company
4:27has a fixed place in UAE when how they
4:29can have a fixed place in UAE, they can
4:31have a branch.
4:34They can have a office, they can have
4:37some u some mine,
4:42oil rig,
4:44it can be anything. If a foreign
4:47company, a UK company is has a presence
4:50in UAE through a fixed place, then it is
4:54called permanent establishment.
4:57Now that UK company required to pay
5:00taxes in UAE only the income which is
5:03generated from the PE
5:06or it can be through people also depend
5:09uh agency PE also. Let's say UK company
5:12has 10 employees in UAE and these 10
5:14employees are working for UK company
5:17sitting in UAE and they are generating
5:19income that means the people in UAE is
5:24considered as a permanent establishment.
5:27Now in entire this when it this is
5:30actually comes to a crossber transaction
5:32issue that transaction between country
5:34to country. When it comes to crossber
5:37transaction there are always always two
5:40topics which we can fight from morning
5:42to evening and nobody is going to win.
5:45First one is PE.
5:48whether UAE company has uh sorry foreign
5:51company has PE in UAE or not or whether
5:55UAE company has a PE outside UAE or not.
5:58Second thing transfer pricing. What is
6:01transfer pricing? We discussed I
6:03remember it was in third chapter.
6:05Transfer pricing means any transaction
6:08which is happening between related
6:10parties uh or connected person it is at
6:13market value. So people can fight yes it
6:16is at market value. the authority can
6:17tell no it's not at market value. So
6:19these two topics also PE um like
6:23companies can tell yes my company has a
6:26PE in UAE my company has no PE in UAE
6:29and authority can give a different
6:30argument. So these two things are very
6:34subjective and uh
6:37we cannot like as I told like if a UK
6:39company has three four people in UAE the
6:42UK company can tell it's not a PE UA tax
6:45authority can tell it's a PE and in the
6:47entire world there is a lot of cases
6:49happening in in uh in and around about
6:53permanent establishment and if you see
6:56the country which has the most
6:58interesting and most number of PE cases
7:01is India India.
7:03You can check in internet. There are a
7:05lot of permanent establishment related
7:08cases uh which happened in India. There
7:11was a case of Formula 1.
7:16Formula 1 put a track a racing track in
7:20India and Indian income tax authority
7:23told it's a PE. That track is a PE. Uh
7:26second, recently there was a case of a
7:30UAE based hotel.
7:34This was happened I believe in 2025.
7:37The the UA I forgot the name. I think it
7:40was Hayat or some some group they uh
7:43like Indian income tax authority told
7:45like they have a PE in India because
7:47they are consulting other uh hotel
7:50groups etc etc. So permanent
7:53establishment is a very subjective
7:56concept which like you know countries
8:00and tax authority versus companies are
8:02keep fighting. It will never end.
8:06Now coming back to our topic if a
8:09foreign company has a permanent
8:11establishment in UAE then in that case
8:14that foreign company need to pay taxes
8:17in UAE. In so far the income the foreign
8:21company generated through this permanent
8:23establishment.
8:26If they have a permanent establishment
8:29then the next question is like when they
8:31need to register
8:34when they need to register.
8:37Once they registered
8:39then the next question is when they need
8:41to
8:43file tax return. the same flow which we
8:46discussed about resident
8:49then when they need to dregister.
8:55Now before getting into this let me give
8:57a little more uh idea about these
8:58things.
9:00Let's take an example of branch.
9:03If a UK company is opening a branch they
9:07may be having a trade license.
9:09Just because they have a trade license
9:12does that mean they have a PE in UAE?
9:14No,
9:16just because they don't have a trade
9:18license, that doesn't mean they don't
9:20have a PE. So PE is a concept. We need
9:24to realize or analyze that whether a
9:27foreign company has a PE in UAE or not.
9:30[snorts] As I told if a UK company take
9:34a branch license in UAE, they have not
9:36taken any office. They don't have any
9:38employee. They just have a trade
9:39license. That trade license itself
9:41cannot become a PE in UAE.
9:45UK company has a trade license and bank
9:47account. Bank account cannot be
9:49considered as a PE.
9:52Now on the flip side, UK company does
9:54not have a trade license but most of
9:56their employees are sitting in UAE and
9:58working. That means even though they
10:00don't have a trade license in UAE, it
10:03can be considered as a PE. When it comes
10:06to PE, the safe word we you need to
10:10always use is may because we cannot tell
10:13will, should, can. It will be always may
10:17because nobody can give guarantee
10:19whether it's a PE or not.
10:25I've seen like many many companies they
10:27have they have opened representative
10:30offices branches in UAE and when the
10:33corporate tax deadline was kicking like
10:35then uh many companies like you know
10:38misunderstood the law or they misread
10:40the interpretation and uh they got got
10:44into the registration. Now when they
10:46registered when they are filing they
10:49need to pay taxes on the income which is
10:51attributable to this PE
10:55they don't have any operation they don't
10:56have any employees then they don't have
10:58any income which is attributable to this
11:00UA branch then obviously the question is
11:03there in why they registered in first
11:06place so a foreign entity need to
11:09register in UAE after doing a proper
11:13permanent establishment analysis is if
11:16they identified that we don't have a PE
11:19in UAE that means they don't require to
11:22register for register in UAE.
11:26Now when and one more thing when you
11:29approach any non-resident thing see
11:31resident is someone who is registered in
11:34UAE they are doing business in UAE it
11:36can be natural resident natural or
11:38jurorical when it comes to non-resident
11:42we need to always always refer a
11:45document called DTA
11:48some some places it's called DTAWA what
11:51does that mean double tax avoidance
11:53agreement or double tax agreement and
11:55DTA, DTAA. What is DTA? DTA means an
11:59agreement signed between
12:04two countries.
12:09Always refer the DTA. What is written in
12:13DTA about permanent establishment?
12:16I think it is generally uh explained in
12:20article five or six in DTA. Always there
12:26will be a clause about permanent
12:27establishment. When a foreign company
12:30can consider as a permanent
12:32establishment in another country, this
12:34is always explained. Now before making a
12:37judgment that okay they have a like you
12:41know the foreign company
12:43is doing some construction in in UAE
12:47before making a judgment yeah they are
12:48doing a construction it's a PE or they
12:51are providing any long-term services in
12:53UAE it's a PE always go back to the DTA
12:56and read what is written in the DTA
12:59about the PE concept and maybe they will
13:02tell even if a UK company is doing some
13:06activity through a fixed place but that
13:10activity is for a short term let's say
13:12for 3 months then it is not considered
13:14as a P I'm just giving a hypothetical
13:16example to you
13:18whereas if we make an interpretation
13:21that the foreign company is conducting a
13:23business activity in UAE through a fixed
13:25place and uh then they are a PE they
13:28need to register that will more likely
13:31go wrong.
13:34So always refer DTAA to understand
13:37whether the foreign company has a PE or
13:40not. If they have a PE, the foreign
13:44company have a PE then that means they
13:47need to register for corporate tax. when
13:50they need to register for corporate tax.
13:51They need to register for corporate tax
13:54within
13:586 months
14:01of PE
14:03established.
14:06Now the authority doesn't know when you
14:09got established your PE. As I told just
14:11because you have a trade license, you
14:13you should not consider 6 months from
14:15the date of trade license because you
14:18don't have a trade license you should
14:20not say like I don't have a trade
14:21license. Always understand on which day
14:25you established your PE in UAE and from
14:28that day within 3 months or within 6
14:31months you the foreign PE required to
14:35register for corporate tax and once they
14:38registered for corporate tax then they
14:40need to file the annual tax return
14:44and once the the PE is uh there is no
14:46more PE they they like you know example
14:49they had three four employees now Those
14:51employees moved from UA to outside now
14:54then there is no PE that means then they
14:56can dregister then dregistration is also
15:00within 3 months
15:03from no PE
15:07from no PE. So a foreign company
15:10required to register the first scenario
15:12the foreign company has a PE in UAE.
15:15All these things about permanent
15:17establishment in UAE is explained in
15:20article 14 of corporate tax law. If you
15:24remember in the previous chapter we told
15:26we are going to discuss article 11 to
15:28article 15. [clears throat] So article
15:3114 is talking about uh permanent
15:34establishment. Following to that article
15:3715
15:40is explaining about investment
15:44manager
15:47exemption.
15:49Now think of a situation a foreign
15:52company want to invest
15:55uh in shares or bonds or or like you
15:58know something in in UAE and they found
16:01out a investment manager in UAE to
16:04handle their investment. It's a third
16:07party
16:09and the investment manager or investment
16:12management company. It is their ordinary
16:14business
16:16that they are doing this for others
16:18also. Investment management
16:22also investment manager is getting paid
16:25for the service
16:29for service because they are managing
16:30the portfolio
16:33at market value.
16:39Now the question is is this investment
16:41manager can be considered as a PE for
16:44the foreign company. If the investment
16:46manager become a PE what is going to
16:49happen the foreign company required to
16:51register in UAE. So here article 15
16:54explained that
16:56if a foreign company has some investment
16:58in UAE and it is managed by an
17:02independent uh investment manager and
17:05that investment manager is getting paid
17:07at market value and that the activity
17:10what the manager is doing is in the
17:12ordinary course of business of that
17:14particular person
17:16then it is not a PE just because someone
17:19is managing a foreign company's
17:21investment and this conditions are
17:23satisfied then it is not a PE. This is
17:26what explained in article 15 of the UA
17:30corporate tax law.
17:32Now moving into the second category of a
17:36situation where a foreign company need
17:38to register. First we told PE second we
17:41told Nexus.
17:43What is nexus?
17:46In corporate tax law, it's just told if
17:48a foreign company has a nexus in UAE,
17:51then the income generated from that
17:53nexus will be subject to corporate tax.
17:56This is what explained in tax law. Now,
17:59what is nexus? This uh things explained
18:03in cabinet decision number
18:1056 of 2023.
18:13The uh literal meaning of nexus you can
18:16say like you know connection
18:21what is the foreign company's connection
18:22in UAE what is the foreign company's
18:24nexus in UAE it can be anything it was
18:27so much of confusing when the tax law
18:29came what they mean by nexus then later
18:32a cabinet decision got published 56 of
18:352023 and it clearly explained that nexus
18:38means
18:41nexus means
18:44Immovable
18:46properties.
18:51Immovable properties. Example, if a UK
18:55company has a real estate in UAE which
19:00is owned by a UK company, this real
19:02estate property can be considered as a
19:05nexus. So if a foreign company has any
19:07immovable property in UAE, it's not only
19:10always real estate, it can be any
19:12immovable property. Then that foreign
19:15company is considered having a nexus in
19:19UAE. Foreign company is considered
19:21having a nexus in UAE. If they have a
19:24nexus, then
19:26they need to pay the taxes on the income
19:28generated from Nexus. Now this cabinet
19:30decision number 56 of 2023 is gave a
19:35blanket rule that if a foreign entity
19:37has a uh immobile property in UAE then
19:41that immobile property will be subject
19:43to corporate tax that will means that
19:45foreign company has a nexus in UAE.
19:48Further in 2025 there is a new cabinet
19:51decision issued which is cabinet
19:53decision number 35 of 2025
19:57which further explained that if a
20:00foreign company has some investment in
20:03UAE and that investment they have made
20:05through some qualifying investment fund
20:09or real estate investment trust
20:13then subject to certain conditions they
20:15can avoid this nexus. We will discuss
20:18that in later stage. It is a bit
20:20complication complicated. There are
20:22certain percentages. All these things
20:24are there. For your current
20:25understanding, it is good enough to
20:27understand that if a foreign company has
20:30a uh immobile property in UAE, that
20:34means that foreign company has a nexus
20:36in UAE. And if they have a nexus in UAE,
20:38the income generated from that uh nexus
20:41will be subject to corporate tax. If
20:45they have a nexus then the next question
20:47is when they need to register.
20:51They need to register within 3 months
20:55from
20:57the day
20:59Nexus is there
21:02then they need to file. When they need
21:04to file same within 9 months from the
21:07end of tax year once the nexus is not
21:11there then they can they need to
21:13dregister also
21:16again when they need to dregister within
21:183 months.
21:20So this is about nexus in short a
21:22foreign company has a real estate uh or
21:24a mobile property in UAE. If yes it is
21:27considered as a nexus. From the day they
21:29have nexus they need to register and
21:31file the annual tax return and when the
21:33nexus is not there within 3 months they
21:35need to dregister also.
21:39Now the third last category is source
21:42income.
21:44If a foreign company has a PE or nexus
21:49then they need to register.
21:52What if a foreign company is earning
21:53some income from UAE
21:57and they don't have PE or they neither
22:00have PE nor uh have uh nexus what what
22:03could be the situation I'll give you
22:05certain source income example
22:09service provided
22:14interest earned and
22:22IP income.
22:24Now if a foreign company let's let's say
22:28a US company this US company is
22:31providing some services to a UAE company
22:34one Indian company and this company has
22:38a fixed deposit in UAE bank and one uh
22:42Canada company Canadian company they
22:45have they are getting some royalty from
22:48their intellectual property they have
22:50some trademark or patent and that they
22:53have given to a UA company and they are
22:55getting uh royalty from these things.
22:57What will happen in this situation? Is
22:59it a PE? No.
23:02US company provided services to UAE
23:05company. If they have provided this
23:07service through like you know a PE means
23:10through a branch or through an office or
23:13through a agency then that can be a PE.
23:16If it is a PE then they need to register
23:19file everything will come in picture.
23:24If uh Indian company has a fixed deposit
23:27in UAE from where the income is
23:29generated the interest income is
23:31generated from UAE only. But does that
23:35mean the Indian company uh has a PE in
23:37UAE? No. Is it an excess? No. Then what
23:40will happen then it is considered as a
23:42source income.
23:45Same way IP income. they give a
23:48trademark or a patent to a UA company,
23:50Canada company and UAE company is paying
23:54uh royalty out of it for the IP which is
23:57getting used. Now from where Canada
24:00company is getting this income, this
24:01income is sourced from UAE. Does the
24:04Canada company uh require to register
24:07here? No, there is no if there is no PE
24:10no excess then no need to register but
24:13it is still a UAE source income. So if
24:16there is a UA source income, it is
24:19explained in article
24:2213
24:25that if there is a source income from
24:28UAE then that means it is subject to
24:32withholding tax.
24:36Withholding tax means when a UAE company
24:39paying for this particular uh services.
24:44Let's say we told like US company
24:46provided some services to UAE company.
24:49When UAE company paying the service
24:51charges, they are going to deduct
24:53certain amount. They're going to deduct
24:56certain amount and balance they are
24:58going to pay to us.
25:00Now this is called withholding tax. tax
25:03deducting at the source and balance will
25:06be paid. That means then they're telling
25:08okay we have taken our part of taxes now
25:12you can take the money you don't need to
25:13register here because you are a foreign
25:16company like UAE cannot ask every
25:18foreign company to come and register
25:20here but at the same time uh it is very
25:23important to have a withholding tax
25:26otherwise what is going to happen there
25:28is a huge chance that uh the companies
25:32in UAE they are going to take services
25:35from outside UAE
25:37When there is a withholding tax the
25:39companies will think that okay if we are
25:42taking this outside UA then we need to
25:44deduct the withholding tax and pay. If
25:47it is within the country then there is
25:48no withholding tax. Withholding tax is
25:50coming under the cross uh concept of
25:54crossber transaction.
25:57Withholding tax is explained in
25:58corporate tax law article 45. Article 45
26:02has explained uh about withholding tax.
26:05Currently withholding tax is at 0%.
26:09Now the difference is that why they told
26:110% when there is no withholding tax.
26:14It's not that there is no withholding
26:15tax. They told withholding tax is
26:17applicable in UAE but currently the rate
26:20is 0%. So there is a higher possibility
26:23that in future authority will come and
26:25tell uh this is the withholding tax
26:28rate. Example let's say 5 percentage or
26:307 it can be any percentage. So right now
26:33it is at 0%age.
26:37In short we are discussing about foreign
26:41company. Foreign company they are taxed
26:44in UAE in three situation. Situation
26:46number one if they have a PE. If they
26:48have a PE it can be uh branch, it can be
26:52office, it can be anything like you know
26:54which is considered as a PE. If yes that
26:57means they need to register here. always
27:00refer the DTAA and uh uh based on the
27:04DTAA we need to make a determination. If
27:07there is a PE they need to register they
27:09need to file the tax return and once the
27:11PE is not there they need to dregister
27:13also. Nexus. Nexus we discussed that the
27:16there are two cabinet decision. Cabinet
27:18decision number uh 56 of 2023 and 35 of
27:222025. Uh like we discussed that if a
27:25foreign company has a real estate
27:27investment or a immobile property
27:29investment in UAE then that is
27:31considered as a
27:33uh nexus in UAE. And uh if they have a
27:38nexus within 3 months they need to
27:41register and file the tax return. And
27:43once they don't have an access they need
27:45to dregister. Also if a foreign company
27:48is getting any other income from UA
27:50source neither through PE nor through uh
27:55nexus then it is considered as UA source
27:58income and UA source income currently
28:01subject to withholding tax and the
28:03withholding tax rate right now it is 0%.
28:07This is about the whole thing. Now we
28:11discussed about resident
28:14we discussed about non-resident
28:19certain
28:21uh certain like you know benefits about
28:24taxes which is applicable for both
28:27resident and non-resident
28:29certain things are exclusively for
28:32resident now if I'm telling 375,000
28:36dhams is zero tax
28:38for a non-resident also it up to 375,000
28:41dham it is 0%age tax. So this is this
28:44threshold is available for both resident
28:46and non-resident.
28:48We discussed about free zone. We
28:51discussed about qualifying free zone
28:52person. That means a freezone company
28:55subject to uh conditions they will be
28:58eligible for 0%age corporate tax. This
29:01benefit is available for resident free
29:03zone company also.
29:07A foreign company who has a PE or like
29:10you know a branch branch of a foreign
29:13company also can get a qualifying free
29:15zone benefit.
29:17So like this certain benefits are
29:19available for uh resident also
29:21non-resident also but certain benefits
29:25which are exclusively available for
29:27residents only not available for
29:30non-residents at all. What are all those
29:32benefits which are available for
29:34residents? Number one small business
29:37relief.
29:39Small business relief is available only
29:41for residents.
29:44This resident can be georitical also,
29:47natural also.
29:50So if a individual
29:52natural person who is conducting
29:54business and getting more than 1 million
29:57got registered
30:00if that person is getting revenue in a
30:02year below 3 million dhams
30:06and uh like regardless that person is a
30:08natural person or judical person as long
30:10as the person is a resident then that
30:13person can get small business relief.
30:15Second one tax group
30:19which we are yet to discuss. Tax group
30:21means two or more companies can create a
30:25group and after creating the group they
30:28are going to have one tax registration
30:30number and one tax filing. So this tax
30:33group why people should do is it good to
30:35do what are all the conditions
30:38when it is recommended we will discuss
30:40when the tax group things comes
30:43but for the time being tax group can be
30:46made only by residents.
30:49A foreign company's branch cannot make a
30:52tax group. Third thing
30:56qualifying
30:58group relief.
31:00Qualifying group relief again this all
31:03will come in the subsequent chapters.
31:05Qualifying group relief means two
31:08companies two companies can transfer the
31:11assets or liabilities between the
31:13companies. There are conditions there
31:15should be 75%age ownership and all.
31:17There are conditions for that. If the
31:19conditions are satisfied company A can
31:22transfer the assets to company B without
31:26gain or loss. Whatever at the cost they
31:28can transfer. So that means there will
31:30be no uh profit generated in this
31:33transaction and there will be no tax
31:35applicability on this transactions.
31:38This qualifying group relief is
31:40available only for a resident uh person.
31:46Fourth one is loss transfer.
31:51In UAE corporate tax law, a company who
31:54made a loss can transfer their loss to
31:57another company who made a profit.
32:00Again, there are conditions for this. We
32:02will we will discuss like there are
32:04three articles which is exclusively
32:06talking about losses and loss transfer
32:09and loss carry forward. But for the time
32:11being it is loss can be transferred
32:13between companies. If company A made 1
32:16million loss and company B made 2
32:19million profit, company B can take this
32:21loss from company A and reduce the
32:24profit and pay the taxes on the
32:26difference. This loss transfer is
32:28available only for uh
32:32only for uh resident uh persons not for
32:36the non-resident person. Now it's a
32:38matter of subjective question. Uh
32:40example, this is especially for those
32:42who are into consultancy. your client is
32:44coming and asking I I'm a foreign
32:46company and I'm thinking of setting up
32:49something in UA should I set up a uh
32:53branch or a subsidiary see there are
32:56positive side also negative side also
32:58for everything now I always analyze this
33:02things that when it comes what is the
33:04actual requirement whether they should
33:06go for a standalone company or a
33:08subsidiary or a branch and one of the
33:10things what I consider is on the
33:12corporate tax benefits
33:14If they become a cor uh like a
33:17subsidiary they can be getting certain
33:19benefits like as I told small business
33:21relief small business relief cannot be
33:24availed if someone who is setting up a
33:26company in UAE as a branch. So it is
33:29highly subjective. Now
33:33last two chapters what we have discussed
33:35is on the taxable person. we discussed
33:38uh about uh resident and uh jurical
33:42natural person we discussed about the
33:44same way for the non-resident as well.
33:48Now we have discussed about taxable
33:51person. Now then next what we are going
33:53to discuss
33:55which I will consider it as a bit of
33:58boring uh chapters which is exempt
34:01person. Why it is a bit boring that also
34:05I will tell to you. Exempt person is not
34:08something on a day-to-day things which
34:10we will see once once in a blue moon we
34:13will get uh to deal with some exempt
34:15person not to everyone I'm just telling
34:18my personal opinion uh like you know uh
34:21there there there are uh qualifying
34:24investment fund qualifying charitable
34:26trust all these things on a day-to-day
34:28basis what we are dealing is taxable
34:30persons those who are subject to tax uh
34:33and they are paying taxes on the
34:35different different rates But yes, we
34:37will touch upon exempt person also in
34:39next chapter. And uh see you in next
34:42chapter.

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