Switzerland · Residence · Lump-sum taxation

Swiss residence permit through lump-sum taxation (expenditure-based taxation)

A Swiss residence permit for wealthy foreign nationals who do not work in the country: instead of income tax on worldwide income, a tax on expenditure (the lump-sum regime) agreed with the canton. The law requires no investment in property, funds or business: the legal basis for residence is the canton's substantial fiscal interest. A B permit for one year with renewals, a permanent C permit after 10 years. This is residence, not citizenship: the Indian passport stays untouched.

Facts verified October 8, 2026 against official sources · Sources

Conditions in brief

Facts verified October 8, 2026 against official sources · Sources

Legal basis for residence
Art. 30 para. 1 (b) AIG + Art. 32 VZAE'substantial cantonal fiscal interests': the canton decides, the SEM approves. Applicants aged 55 and over have a second route, the retiree permit (Art. 28 AIG), which requires special ties to Switzerland
Tax
On expenditure, not incomethe base is the family's annual living costs, but not less than CHF 435,000 (2026), seven times the rent and the control calculation on Swiss-source income; the ordinary federal, cantonal and communal scale is applied to that base
Work
Not allowed in Switzerlandany work in the country ends the regime for both spouses; managing your own assets is allowed. Under the fiscal-interest permit work is possible abroad only
Processing
No statutory termtwo stages: a preliminary tax agreement with the canton, then the residence permit with SEM approval. In practice it takes months, but there is no statutory deadline and we do not promise one
  • Lump-sum taxation (Besteuerung nach dem Aufwand) is the right of a foreign national who becomes a Swiss tax resident for the first time or after a break of at least 10 years, and who does not work in the country, to pay tax on expenditure instead of income tax (Art. 14 of the Federal Direct Tax Act, DBG; Art. 6 of the Tax Harmonisation Act, StHG, for the cantons). There is no 'residence by investment' programme in Switzerland.
  • The tax base is the family's annual worldwide living costs, but not less than CHF 435,000 at federal level in 2026, seven times the annual rent or rental value of the home, and the sum of Swiss-source income under the control calculation. It is a base, not the tax bill: the tax is calculated at the ordinary federal, cantonal and communal rates.
  • The legal basis for residence for nationals of countries outside the EU and EFTA is the canton's substantial fiscal interest (Art. 30 para. 1 (b) AIG, Art. 32 VZAE): the canton decides, the SEM approves. The law requires no investment in property, funds or business. The regime has been abolished in the cantons of Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt.
  • The first B permit is issued for 1 year and renewed under the ordinance for 2 years while the conditions hold; the permanent C permit comes after 10 years, or after 5 with a good command of the local language. Citizenship requires a C permit and 10 years of residence, 3 of them in the last 5; naturalisation ends the right to the lump-sum regime.
  • The spouse and children under 18 receive residence through family reunification (Art. 44 AIG); both spouses must meet the regime's conditions. For Indian families nothing changes about the passport: this is residence, not citizenship. The budget is significant and only makes sense for families who will genuinely live in Switzerland.

What you get

Tax on expenditure, not on income

Worldwide income and assets abroad are not declared line by line: the base is the living costs agreed with the canton. The tax is predictable years ahead.

No mandatory investment

Swiss law does not require you to buy property, place money in a fund or open a business for this regime. The basis is the canton's fiscal interest, not a transaction.

The family together

The spouse and minor children receive residence through family reunification; their costs go into the same tax base, with no separate minimum per person.

Schengen without a visa

With a Swiss residence permit you enter the other Schengen countries without a visa and spend up to 90 days there in any 180 days.

Time counts towards the C permit and citizenship

Years on a B permit count: a permanent C permit after 10 years, citizenship with a C permit and 10 years of residence.

The passport stays

This is a residence permit and a tax regime, not citizenship. The Indian passport is unaffected, and a canton is chosen for the family's budget, schools and language, not for an advertised rate.

Official requirements

Facts verified October 8, 2026

No Swiss citizenship
The regime is available to foreign nationals only. If one spouse is a Swiss citizen or becomes one, both lose the right to lump-sum taxation (Art. 14 para. 2 DBG; ESTV Circular No. 44, section 2.4).
First move or a 10-year break
You become subject to unlimited tax liability in Switzerland for the first time or after a break of at least 10 years. Someone previously taxed on expenditure who left can return to the regime regardless of the 10-year rule.
No work in Switzerland
Any main or secondary occupation in the country, including a paid board seat, excludes the regime. Managing your own assets is allowed. Under a permit on the fiscal-interest basis, work is possible abroad only (Art. 32 para. 2 VZAE; SEM Directives, section 5.5).
Tax base: 2026 minimums
Not less than the highest of: CHF 435,000 (federal minimum, Art. 14 para. 3 (a) DBG, indexed by the FDF); seven times the annual rent or rental value of the home; three times the annual boarding cost for those without their own household; and the sum of Swiss-source income and income on which treaty relief is claimed (control calculation). The canton may set its own minimum (Art. 6 para. 3 (a) StHG) and decides how the regime covers wealth tax.
Legal basis for residence
For non-EU/EFTA nationals, a permit under Art. 30 para. 1 (b) AIG and Art. 32 para. 1 (c) VZAE: the canton confirms a substantial fiscal interest, the SEM gives its approval (Art. 85 VZAE). You must show that the centre of your life moves to Switzerland and that you will spend most of your time in the country. The alternative for applicants aged 55 and over is the retiree permit (Art. 28 AIG, Art. 25 VZAE): special personal ties to Switzerland and means above the supplementary-benefits threshold; owning property is not a tie.
Housing and means
A home in the chosen canton, rented or owned; the minimum of seven times the rent is calculated from it. Proof of means to live without social assistance and Swiss health insurance for the whole family.
Reputation and source of wealth
The canton and the SEM weigh the fiscal interest against Switzerland's interest in protecting its reputation (SEM Directives, section 5.5): the origin of the capital is checked and sanctions restrictions are taken into account.

Government fees and timelines

Federal minimum base (2026)CHF 435,000 a year
Art. 14 para. 3 (a) DBG, FDF indexation from 1 January 2026; CHF 434,700 in 2025
Housing minimum7 × annual rent
or the rental value of an owned home; 3 × boarding cost for those without their own household
Tax rateOrdinary scale
federal, cantonal and communal tax on the agreed base; the canton decides how wealth tax is covered
Cantonal minimum basePer canton
set by cantonal law (Art. 6 para. 3 (a) StHG); stated after the canton is chosen and the tax authority's position obtained
Permit feesPer cantonal tariff
depends on the canton; confirmed on the filing date
ProcessingNo statutory term
tax agreement, cantonal decision, SEM approval; practical timelines are not statutory

How the process works

  1. Diagnosis and choice of canton1–2 weeks

    Nationality, sources of income and wealth, family composition, preferred region. We exclude the cantons without the regime and estimate the base.

  2. Preliminary tax agreementdepends on the canton

    Request to the cantonal tax authority: living costs, seven times the rent and the control calculation. We obtain the canton's position on the agreed base.

  3. Housing and dossier2–6 weeks

    Lease or purchase of a home, proof of means and source of wealth, insurance, apostilled police certificates, translations, justification of the canton's fiscal interest.

  4. Filing with the cantonal migration officeby appointment

    Application for a B permit under Art. 30 para. 1 (b) AIG. The canton decides and forwards the file to the SEM.

  5. SEM approval and entryno statutory term

    The SEM gives its approval (Art. 85 VZAE), the consulate issues a D visa; after entry, registration with the commune and biometrics for the B card.

  6. Living in the status and renewal1 year, then 2 years

    Return under the lump-sum base, control of work restrictions, permit renewal. After 10 years, application for the C permit.

How people actually use it

The official conditions are above. Below is how the regime works in real life, from our cases and research.

Assessed through the canton and the family's profile

The regime makes sense only through a specific canton and family. The deemed-income figures quoted around it are a tax base, not necessarily the annual tax bill, and certainly not the price of a residence permit.

Not available everywhere, and not with everything

Five cantons have abolished lump-sum taxation; the others apply their own minimums. The regime comes with restrictions on professional activity in Switzerland, for the second spouse too.

Tax and residence are two separate procedures

Beyond the tax calculation, a separate legal basis for residence is required, especially for nationals of countries outside the EU and EFTA, which includes Indian nationals. We start with a preliminary position from the cantonal authorities.

The full budget, not the rate

Tax, housing, healthcare and daily costs must add up to an acceptable total: one attractive rate does not show the real cost of the move.

Andrey Boyko

Switzerland's expenditure-based tax regime — often called lump-sum taxation — should be assessed through the specific canton and the family's profile. The deemed-income figures quoted around it are a tax base, not necessarily the annual tax bill, and certainly not the price of a residence permit.

The regime is not available everywhere and comes with restrictions on professional activity in Switzerland. Beyond the tax calculation, a separate legal basis for residence is required — especially for citizens of countries outside the EU and EFTA, which includes Indian nationals.

We start with a preliminary position from the cantonal authorities and a full family budget. Tax, housing, healthcare and daily costs must add up to an acceptable total: one attractive rate does not show the real cost of the move. As with the other European routes here, this is residence rather than citizenship — the Indian passport is not at stake — but the commitment is significant and only worth it for families who will genuinely live there.

Andrey Boyko, Founder & Managing Partner · September 11, 2026

Fiscal-interest permit or retiree permit: which route fits

Permit on the canton's fiscal interestRetiree permit (Art. 28 AIG)
Legal basisArt. 30 para. 1 (b) AIG, Art. 32 para. 1 (c) VZAEArt. 28 AIG, Art. 25 VZAE
AgeNo limit55 and over
Ties to SwitzerlandNot required; the centre of life must move to the countryRequired: earlier stays, close relatives; property does not count
WorkAbroad only; managing your own assetsNowhere, except managing your own assets
TaxLump-sum regime agreed with the cantonLump-sum regime under the same Art. 14 DBG conditions
DecisionCanton + SEM approvalCanton + SEM approval
FamilySpouse and children under 18 under Art. 44 AIGSpouse and children under 18 under Art. 44 AIG

Conditions under the AIG and VZAE as in force in 2026 and the SEM Directives (as at 15 June 2026); re-checked on the filing date.

Who the programme is for

Who this programme suits in our practice.

Owners of businesses outside Switzerland

You receive dividends and income from companies outside Switzerland and do not plan to work in the country. Tax is calculated on expenditure, not on worldwide income; a paid position in a Swiss company already breaks the regime.

Rentiers and investors

You live on income from capital and property. Swiss sources, such as dividends of Swiss companies, property in the country and income on which treaty relief is claimed, enter the control calculation and can raise the tax.

Applicants aged 55 and over with ties to Switzerland

Earlier long stays, studies or close relatives in the country open the retiree route under Art. 28 AIG. Owning property does not count as a tie.

Nationals of countries outside the EU and EFTA

Indian, UAE and other non-EU nationals need a separate legal basis for residence, which is what this page is about. For Indian families the attraction is that the passport is not at stake: it is residence, not citizenship.

Service packages

Our fee depends on the canton and the family composition. We send the quote in reply to your message.

Turnkey filing

Main applicant

  • Free preliminary audit: nationality, sources of income and wealth, family composition, choice of canton
  • Tax-base calculation: living costs, seven times the rent, control calculation on Swiss-source income
  • Request for a preliminary position (ruling) from the cantonal tax authority
  • Residence dossier: proof of means, housing, insurance, apostilled certificates, translations
  • Filing with the cantonal migration office and support through SEM approval and the B card

Fees of licensed local lawyers and authorised agents are charged separately at their rates

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Turnkey filing + family

Applicant with spouse and children

  • Everything in the Turnkey filing package
  • Check of the regime's conditions for both spouses (Art. 14 para. 2 DBG)
  • Inclusion of the family's costs in the tax base and assessment of the consequences
  • Dossier for each family member and filing under Art. 44 AIG
  • Control of reunification deadlines: 5 years, 12 months for children over 12

Fees of licensed local lawyers and authorised agents are charged separately at their rates

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Residence for the whole family: who can be included

For Garant IN the family is a core value: residence is arranged for your relatives together with you under the AIG family reunification rules (Art. 44 and 47), and the tax regime covers the whole family's expenditure. Below are the 2026 conditions from the law, without generic phrases.

  • Spouse

    The spouse receives a permit through family reunification (Art. 44 AIG): living together, adequate housing, no social assistance, a conversational command of the local language or registration for a language course at first issue. For the lump-sum regime both spouses must meet the conditions: no Swiss citizenship and no work in Switzerland (Art. 14 para. 2 DBG). A registered partnership is treated as marriage; an unregistered partner has no right to reunification.

  • Children

    Unmarried children under 18 join you at the same time or later, with no language requirement. The deadline for reunification is 5 years, and 12 months for children over 12, counted from the issue of your permit (Art. 47 AIG); after that only for important family reasons. Adult children are not covered by Art. 44 and need their own legal basis.

  • Parents

    The law gives B permit holders no right to reunification with parents. Parents aged 55 and over may consider their own retiree permit (Art. 28 AIG) with special ties to Switzerland and sufficient means, or their own lump-sum agreement. We do not promise this; we check it canton by canton, including for the multi-generation households we often see from India.

  • Family budget

    The expenditure base includes the costs of everyone you support, including abroad (ESTV Circular No. 44, section 3.2): schools, housing, staff, travel. The CHF 435,000 minimum and seven times the rent apply per household, not per person; the spouse's and children's costs paid from their own funds also go into the base. The family needs insurance and proof of means without social assistance. For India-resident families the funding of living costs from abroad is planned within the LRS framework.

Filing is together with the main applicant or later within the Art. 47 AIG deadlines; the canton decides on the family with SEM approval. Garant IN's migration programme experts check each family member's documents in advance to rule out a refusal for an individual applicant. Verified on 2 October 2026 against the AIG, VZAE, DBG and ESTV Circular No. 44.

Garant IN

What we do that others will not

The law is the same for everyone. The difference is the canton, the base calculation and how honestly the full cost of the move was worked out before the agreement was signed.

  1. The canton's position first, documents second

    We request a preliminary position from the cantonal tax authority and the migration office before assembling the dossier: which canton will accept, what base it will agree, how it views the source of wealth.

  2. A base, not a 'price of residence'

    The deemed-income figures quoted around the regime are a tax base, not the annual tax bill and not the price of the status. We calculate the actual tax under the cantonal and communal scale, wealth tax and the control calculation on Swiss-source income.

  3. The full family budget

    Tax, housing, healthcare and daily costs are added into one figure: one attractive rate does not show the real cost of the move.

  4. Work restrictions in advance

    We work out which of your activities are permitted (managing assets) and which break the regime (paid positions in Switzerland), for both spouses.

  5. Straight talk on nationality and practice

    We explain the SEM's current position, Switzerland's reputational interest and the realistic chances in a specific canton before you spend time and money. For India-resident families we also plan how living costs are funded from abroad.

Wording pending approval.

What this regime is and who it suits

Lump-sum taxation is the everyday name. In the law it is taxation on expenditure (Besteuerung nach dem Aufwand, imposition d’après la dépense): a foreign national who moves to Switzerland and does not work in the country pays tax not on worldwide income but on an amount of annual living costs agreed with the canton. The regime has existed at federal level in its current form since 1 January 2016 and in the cantons that have kept it.

Three kinds of applicants choose it. First, owners of businesses outside Switzerland who live on dividends and manage their companies remotely. Second, rentiers and investors with income from capital and property outside the country. Third, families who choose Switzerland as a place to live and educate their children and are ready to move the centre of their life there, not merely to hold a card. For Indian families it has the advantage of every residence route: the Indian passport stays.

It does not suit anyone who plans to work in Switzerland, including paid positions in Swiss companies, or anyone looking for ‘residence by investment’ at a fixed price: there is no investment and no single price here, only a tax agreement with the canton and a discretionary decision on residence.

What comes next

Renewal of the B permit

The first permit is for 1 year, renewal under the ordinance for 2 years (Art. 58 VZAE) while the conditions hold: the tax agreement in force, no work in Switzerland, the centre of life in the country. The canton takes integration into account on renewal.

Permanent C permit

After 10 years with a permit, the last 5 of them uninterrupted, and with integration (Art. 34 para. 2 AIG); with a good command of the local language already after 5 years (para. 4). The C permit is indefinite and unconditional.

Citizenship

Ordinary naturalisation requires a C permit and 10 years of residence, 3 of them in the last 5 before filing (Art. 9 BüG); years between the ages of 8 and 18 count double. Cantonal and communal requirements apply on top. Naturalisation ends the lump-sum regime, and for Indian citizens it would mean giving up the Indian passport.

If plans change

Decide to work in Switzerland and you move to ordinary taxation and another permit type; as a rule there is no way back to the lump-sum regime after giving it up.

4 offices

Moscow, Dubai, New Delhi and Mumbai. Visit an office and see who is working with you.

Membership

  • Garant IN is a member of the Investment Migration Council (IMC), the Geneva-based international association of the investment migration industry. investmentmigration.org →

  • Garant IN is a member of CCI France Russie, the French Chamber of Commerce and Industry in Russia. ccifr.ru →

  • International migration consultancy since 2015.

Who files your application

Two levels of quality control: Garant IN's migration consulting and case management department runs a rigorous pre-application compliance screening (Pre-Due Diligence) and prepares the document package to 2026 requirements, while the application in Switzerland is prepared and filed together with licensed local lawyers and authorised agents. This is how we minimise the risk of refusal at the preparation stage, before the documents reach the government authority.

Frequently asked questions

What is lump-sum taxation and how does it differ from 'residence by investment'?

It is a tax regime under Art. 14 DBG: a foreign national who does not work in Switzerland pays tax not on worldwide income but on an agreed amount of living expenditure. The law requires no investment, property purchase or fund contribution. The residence permit is a separate step, granted on the basis of the canton's substantial fiscal interest (Art. 30 para. 1 (b) AIG); it is a cantonal decision, not a purchase of status.

How much will I pay?

The base is not less than the highest of three figures: CHF 435,000 (the 2026 federal minimum), seven times the annual rent or rental value of the home, and the sum of Swiss-source income under the control calculation; the canton may set its own minimum higher. The ordinary federal, cantonal and communal scale is applied to the base, so the amount depends on the canton and the home. There is no single figure 'for all of Switzerland'; we calculate it for your canton and family.

Do I need to buy property or invest?

No. Swiss law requires no investment in property, funds or business for this regime. You do need a home, rented or owned, and the minimum base of seven times its rent or rental value is calculated from it.

In which cantons is the regime not available?

According to the Federal Department of Finance, lump-sum taxation has been abolished in Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt; Thurgau, St. Gallen, Lucerne and Bern kept it but tightened the rules. The remaining cantons apply their own minimum bases, which we state once the canton is chosen.

Can I work?

Not in Switzerland: any work in the country, including a paid board seat, ends the regime, and for both spouses. Managing your own assets is allowed. Under a permit on the fiscal-interest basis, work is possible abroad only (Art. 32 para. 2 VZAE).

What is the legal basis for residence if I am not an EU citizen?

A permit under Art. 30 para. 1 (b) AIG and Art. 32 para. 1 (c) VZAE: substantial cantonal fiscal interests. It is a discretionary decision: the canton assesses the interest and your move to the country, the SEM approves (Art. 85 VZAE). Applicants aged 55 and over may use the retiree permit under Art. 28 AIG, with special personal ties to Switzerland and sufficient means.

How long does it take?

There is no statutory term. First the cantonal tax authority confirms the base, then the cantonal migration office decides and sends the file to the SEM for approval. In practice it takes months, depending on the canton and the completeness of the dossier; we will not promise 'two months'.

Do I actually have to live in Switzerland?

Yes. For the fiscal-interest permit you must show that the centre of your life has moved to Switzerland and that you spend most of your time in the country (SEM Directives, section 5.5); for the retiree permit renewal is refused if the centre of life turns out to be elsewhere. The lump-sum regime also presupposes tax residence in Switzerland. For Indian residents this means the Indian tax residency position must be reviewed at the same time.

How do I get the C permit and citizenship?

The permanent C permit comes after 10 years with a permit, the last 5 uninterrupted, with integration; with a good command of the local language after 5 years (Art. 34 AIG). Citizenship requires a C permit and 10 years of residence, 3 of them in the last 5 (Art. 9 BüG), plus cantonal and communal conditions. Naturalisation ends the lump-sum regime, and for Indian citizens it would mean giving up the Indian passport.

What about wealth tax?

There is no federal wealth tax, but the cantons levy one. Art. 6 para. 5 StHG leaves it to the cantons to decide how the lump-sum tax covers wealth tax, so some cantons build it into the base calculation. This is one of the points we fix in the preliminary agreement.

Does this affect my Indian passport or LRS?

No. It is a residence permit and a tax regime, not citizenship, so the Indian passport stays. There is no investment to remit, but living costs, rent and tax are funded from abroad, and for India-resident applicants we plan those transfers within the LRS framework. Your Indian tax residency and the India–Switzerland tax treaty are assessed alongside the Swiss status before filing.

I live in India or the UAE. Which documents are needed?

Passports, police certificates from the countries of residence in recent years with an apostille or legalisation (Indian documents apostilled by the Ministry of External Affairs; UAE documents legalised through the UAE Ministry of Foreign Affairs), proof of means and source of wealth, a lease or purchase contract, health insurance, marriage and birth certificates translated into the canton's language.

Can I include parents or adult children in a Swiss lump-sum taxation residence application?

Not through reunification: Art. 44 AIG covers only the spouse and unmarried children under 18. Adult children and parents need their own legal basis: a retiree permit from age 55 with special ties to Switzerland, or a separate lump-sum agreement. We assess each person separately and in advance.

How does the tax base change when applying with a family in Switzerland?

There are no separate minimums per family member: CHF 435,000 and seven times the rent are a minimum per household. But the base is the whole family's worldwide living costs, including children's schools abroad, staff and travel, plus the spouse's and children's costs paid from their own funds. The more the family spends, the higher the base; it cannot go below the minimum.

Do you offer a refund if the application is refused?

Yes. If the application is refused through the fault of our team or an error in building the case, we refund the company's service fee less a minimal retention for costs actually incurred. Refund terms, the payment schedule and the rules on retaining service costs are fixed in the contract before work begins. Before we start, we check your documents and risk history free of charge and tell you about any risks in advance.

Personal cost estimate

An estimate for your family

Message us in the messenger you prefer and you will receive an estimate for your family and route. We never message first: you send the first message.

Our fee depends on the canton and the family composition. We send the quote in reply to your message.

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Programme updates and case breakdowns in our channels.

Sources

Figures and conditions on this page are checked against legislation and official pages. Last verified: .

  1. DBG — Federal Act on Direct Federal Tax, Art. 14 'Besteuerung nach dem Aufwand' (minimum CHF 435,000 from 1 January 2026), Fedlex SR 642.11 · October 2, 2026
  2. ESTV — Circular 2-215-D-2025: cold-progression adjustment for tax year 2026 (table: lump-sum taxation CHF 434,700 → 435,000) · October 2, 2026
  3. ESTV — Circular Letter No. 44 'Besteuerung nach dem Aufwand bei der direkten Bundessteuer' (24 July 2018): conditions, spouses, worldwide expenditure, minimums, control calculation · October 2, 2026
  4. StHG — Tax Harmonisation Act, Art. 6: cantonal minimum base, wealth tax, Fedlex SR 642.14 · October 2, 2026
  5. FDF — Besteuerung nach dem Aufwand: cantons that abolished the regime (ZH, SH, AR, BL, BS), 2014/2016 reform · October 2, 2026
  6. AIG — Foreign Nationals and Integration Act: Art. 28 (retirees), 30 para. 1 (b), 33, 34 (C permit), 44 and 47 (family), Fedlex SR 142.20 · October 2, 2026
  7. VZAE — Ordinance on Admission, Residence and Employment: Art. 25 (age 55, ties, means), 32 (cantonal fiscal interests), 58 (permit validity), 85 (SEM approval), Fedlex SR 142.201 · October 2, 2026
  8. SEM — Directives and Commentary on Foreign Nationals (Weisungen AIG), as at 15 June 2026: section 5.3 (retirees), section 5.5 (fiscal interests, reputation, BVGer F-4448/2023) · October 2, 2026
  9. BüG — Swiss Citizenship Act, Art. 9: C permit, 10 years of residence, 3 of the last 5, Fedlex SR 141.0 · October 2, 2026
  10. SEM — Becoming Swiss: ordinary naturalisation (10 years, 3 of the last 5, C permit) · October 2, 2026

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