FIRST SECTION
\nDECISION
\nApplication no.50821\/06
\nPaolo and Alessandro GUISO and Vincenza CONSIGLIO
\nagainst Italy<\/p>\n
The European Court of Human Rights (First Section), sitting on 16\u00a0January 2018 as a Chamber composed of:<\/p>\n
Linos-Alexandre Sicilianos, President,
\nKristina Pardalos,
\nGuido Raimondi,
\nKrzysztof Wojtyczek,
\nArmen Harutyunyan,
\nPauliine Koskelo,
\nJovan Ilievski, judges,<\/p>\n
and Abel Campos, Section Registrar,<\/p>\n
Having regard to the above application lodged on 11 December 2006,<\/p>\n
Having deliberated, decides as follows:<\/p>\n
THE FACTS<\/strong><\/p>\n 1.\u00a0\u00a0The applicants, Mr Paolo Guiso (\u201cthe first applicant\u201d) and Mr\u00a0Alessando Guiso (\u201cthe second applicant\u201d) are Italian nationals who were born in 1962 and 1960 respectively. Mrs Vincenza Consiglio (\u201cthe third applicant\u201d) was an Italian national who was born in 1929. She died on 2\u00a0February 2008. The first and second applicants are her heirs, and expressed their wish to pursue the proceedings before the Court. They were represented before the Court by Mr. P. Guiso, a lawyer practising in Nuoro.<\/p>\n A.\u00a0\u00a0The circumstances of the case<\/strong><\/p>\n 2.\u00a0\u00a0The facts of the case, as submitted by the applicants, may be summarised as follows.<\/p>\n 3.\u00a0\u00a0The applicants were the joint owners of various parts of different plots of building land in Nuoro.<\/p>\n 4.\u00a0\u00a0The plots in question \u2013 measuring a total surface area of 13,614 square metres \u2013 were recorded in the land register as Folio no. 43, parcel nos. 1141, 1147, 1148, 1339, 1136, 1137, 1143, and 1146.<\/p>\n 5.\u00a0\u00a0By different orders issued between March and October 1991 Nuoro City Council approved a project to build a residential complex on the applicants\u2019 land.<\/p>\n 6.\u00a0\u00a0By four orders issued on 18 October 1991 by the mayor of Nuoro, through an expedited procedure and on the basis of a public interest declaration, the Nuoro municipality was authorised to take possession of the above-mentioned plots of land, with a view to subsequently expropriating them. The deadline for issuing a formal expropriation order was 31\u00a0December 1995.<\/p>\n 7.\u00a0\u00a0In November 1991 the authorities took physical possession of the land and began the building works.<\/p>\n 8.\u00a0\u00a0By an order issued on 12 December 1995 by Nuoro City Council, the deadline for issuing the expropriation order was extended to 31\u00a0October\u00a01996.<\/p>\n 9.\u00a0\u00a0By an order of 21 August 1996 Nuoro City Council further extended the deadline for issuing the expropriation order.<\/p>\n 10.\u00a0\u00a0On 11 October 1996 an expropriation order was issued in respect of the land.<\/p>\n 11.\u00a0\u00a0On 24 January 1997 the applicants lodged an application with the Sardinia Regional Administrative Court (\u201cthe Regional Administrative Court\u201d), contesting the lawfulness of the mayor\u2019s orders of 18 October 1991 and the orders extending the deadline for issuing the expropriation order.<\/p>\n 12.\u00a0\u00a0By a judgment of 12 May 1999 the court found that the orders extending the deadline for issuing the expropriation order had been unlawful, and that the expropriation order of 11\u00a0October 1996 had consequently also been unlawful.<\/p>\n 13.\u00a0\u00a0On 22 November 2000 the applicants applied to the Regional Administrative Court for compensation for their being unlawfully deprived of their property, relying on the same court\u2019s judgment of 12 May 1999. In this connection, they sought an amount equal to the property\u2019s market value on the date when the land had been irreversibly altered, plus a sum reflecting an adjustment for inflation and statutory interest. They further contended that the application of the \u201cconstructive expropriation\u201d rule, which was likely to be applied in their case, had been found by the Court to be incompatible with Article 1 of Protocol No. 1 to the Convention.<\/p>\n 14.\u00a0\u00a0On an unspecified date the courtordered an expert valuation of the land. A report produced in September 2004 stated that the affected surface area of the land was equal to 13,614 square metres, and that the market value of the land in May 1996 had been 122.32 euros (EUR) per square metre.<\/p>\n 15.\u00a0\u00a0By a judgment of 24 January 2005 the court found that, pursuant to the constructive expropriation rule (occupazione appropriativa), the applicants were no longer the owners of the land, which had become the property of the Nuoro municipality following completion of the public works. It dismissed the applicants\u2019 argument that the constructive expropriation rule was incompatible with Article 1 of Protocol No. 1 to the Convention. However, the court conceded that, as the transfer of property had been unlawful, the applicants were entitled to compensation. In this connection, it relied on the expert report which had assessed the market value of the land at EUR 122.32 per square metre. However, the court did not award compensation reflecting the market value, but instead proceeded to make an award based on the criteria contained in Article 5 bis of Legislative Decree no. 333 of 11\u00a0July 1992, as amended by Law no.\u00a0662 of 1996. All amounts were to be adjusted for inflation and include statutory interest from the date the occupation of the applicants\u2019 land had ceased to be lawful, which the court identified as 1 January 1996.<\/p>\n 16.\u00a0\u00a0On 24 May 2005 the applicants lodged an application with the Consiglio di Stato. They contested the lower courts\u2019 legal classification of how they had been deprived of their property and complained that the reduction in their compensation was incompatible with their right to property. They claimed, inter alia, that they were entitled to compensation corresponding to the market value of the land, and a sum for loss of enjoyment of the land. They also complained about the fact that the award would be subject to taxation.<\/p>\n 17.\u00a0\u00a0On 16 February 2006 the Nuoro municipality paid the applicants the amounts due under the judgment of the Regional Administrative Court. The sum they received jointly amounted to EUR 429,814.64. Tax at a rate of 20% was deducted at source from these sums.<\/p>\n 18.\u00a0\u00a0On 2 February 2008 the third applicant died.<\/p>\n 19.\u00a0\u00a0On 2 October 2009 the Consiglio di Stato issued a decision declaring that it did not have jurisdiction to decide the applicants\u2019 claim.<\/p>\n 20.\u00a0\u00a0The applicants lodged an application with the Court of Cassation in order to settle the issue of jurisdiction.<\/p>\n 21.\u00a0\u00a0On 12 January 2011 it ruled, sitting as a full court (Sezioni Unite), that the administrative courts had jurisdiction to decide the applicants\u2019 claim for compensation, as the issue at stake concerned the unlawful exercise of public authority.<\/p>\n 22.\u00a0\u00a0On an unspecified date the applicants resumed their appeal before the Consiglio di Stato. They contested the lower courts\u2019 legal classification of how they had been deprived of their property and complained that the reduction in their compensation was incompatible with their right to property. They asked the court to award an amount corresponding to the property\u2019s market value. They also complained about the fact that the award would be subject to taxation.<\/p>\n 23.\u00a0\u00a0By a judgment delivered on 12 July 2011, filed with the registry on 2\u00a0November 2011, the Consiglio di Stato confirmed that the applicants had been deprived of their property unlawfully. It further drew on the Constitutional Court\u2019s judgment no. 349 of 24\u00a0October 2007, whereby Article 5 bis of Legislative Decree no. 333 of 11\u00a0July 1992, as amended by Law no.\u00a0662 of 1996, had been declared unconstitutional, and held that the applicants were entitled to compensation corresponding to the full market value of the property, minus what had already been paid to them under the judgment of the Regional Administrative Court. The court further stated that the applicants were entitled to a sum reflecting an adjustment for inflation as well as statutory interest from the date that they were deprived of their property. It also awarded them EUR 50,000 in compensation for non-pecuniary damage. The court stated that it lacked jurisdiction to examine the complaint about prospective taxation.<\/p>\n 24.\u00a0\u00a0On 25 May 2012 the Nuoro municipality paid the applicants the remaining amounts due to them under the judgment of the Consiglio di Stato, which amounted to EUR 480,757.76. Tax at a rate of 20% was deducted at source from these sums.<\/p>\n B.\u00a0\u00a0Relevant domestic law and practice<\/strong><\/p>\n 1.\u00a0\u00a0Constructive expropriation (\u201coccupazione acquisitiva\u201d, \u201coccupazione appropriativa\u201d or \u201caccessione invertita\u201d)<\/em><\/p>\n 25.\u00a0\u00a0The relevant domestic law and practice concerning constructive expropriation is to be found in Guiso-Gallisay v. Italy ((just satisfaction) [GC], no. 58858\/00, \u00a7\u00a7 18-48, 22 December 2009).<\/p>\n 26.\u00a0\u00a0In judgments nos. 348 and 349 of 22\u00a0October 2007, the Constitutional Court held that national law had to be compatible with the Convention as interpreted by the Court\u2019s case-law, and consequently declared Article 5 bis of Legislative Decree no. 333 of 11\u00a0July 1992, as amended by Law no.\u00a0662 of 1996, unconstitutional.<\/p>\n 27.\u00a0\u00a0In judgment no. 349 it noted that the insufficient level of compensation provided for by Law no.\u00a0662 of 1996 was contrary to Article\u00a01 of Protocol No. 1 to the Convention and Article 117 of the Italian Constitution, which required compliance with international obligations.<\/p>\n 28.\u00a0\u00a0A number of changes in domestic law occurred following the Constitutional Court\u2019s judgments. Section 2\/89(e) of the Finance Act (Law no. 244) of 24 December 2007 established that, in cases of constructive expropriation, the compensation payable had to correspond to the market value of the property in question and could not be reduced.<\/p>\n 2.\u00a0\u00a0Taxation pursuant to Law no. 413\/1991<\/em><\/p>\n 29.\u00a0\u00a0Law no. 413 of 30 December 1991 (hereinafter \u201cLaw no. 413\/1991\u201d) was created, inter alia, to broaden the tax base and streamline, facilitate and strengthen tax administration.<\/p>\n 30.\u00a0\u00a0The relevant parts of section 11(5) provide that capital gains (plusvalenza) on compensation for expropriation or unlawful forms of acquisition of property (somme dovute per effetto di acquisizione coattiva conseguente ad occupazione di urgenza divenute illegittime) paid to individuals not operating a business are taxable under the Consolidated Income Tax Act (Testo Unico delle Imposte sui Redditi).<\/p>\n 31.\u00a0\u00a0As to the practical means of enforcement of the tax, section 11(7) provides that when paying the compensation mentioned in section 11(5), including, inter alia, compensation for constructive expropriation (risarcimento danni da occupazione acquisitiva) the authorities entrusted with making the payment (enti eroganti) must deduct tax at source at a rate of 20% from the entire sum. It is open to the taxpayer to opt for ordinary taxation in his or her annual tax return, in which case the sum deducted at source will be considered as an advance on the final tax payment due.<\/p>\n COMPLAINTS<\/strong><\/p>\n 32.\u00a0\u00a0The applicants alleged that they had been unlawfully deprived of their land and that the situation had infringed their right to the peaceful enjoyment of their possessions, as guaranteed by Article 1 of Protocol No.\u00a01. They highlighted the fact that the application of the \u201cconstructive expropriation\u201d rule had been found to be incompatible with the Convention on many occasions by the Court.<\/p>\n 33.\u00a0\u00a0The applicants further advanced the argument that, even though the domestic courts had acknowledged the unlawful nature of the expropriation and awarded compensation equal to the property\u2019s market value, adjusted the amount for inflation, added statutory interest and a sum for non-pecuniary damage, they had not received redress that could be considered \u201cappropriate and sufficient\u201d owing to the taxation imposed. In their view, the application of the fiscal measure meant that they had ultimately received a sum amounting to only 80% of the property\u2019s market value. The fiscal imposition therefore reflected a legislative expedient to reduce the costs of acquiring land for public purposes by 20%, though formally disguised as a tax.<\/p>\n 34.\u00a0\u00a0In support of their contention that the situation is incompatible with the Court\u2019s case-law, the applicants pointed out that the Court had always included the phrase \u201cplus any tax that may be chargeable\u201d in its just satisfaction awards in cases involving both lawful and unlawful expropriations. In this connection they cited, amongst other cases, Guiso-Gallisay v. Italy ((just satisfaction) [GC], no. 58858\/00, 22 December 2009, \u00a7 106 and the operative part of that judgment).<\/p>\n 35.\u00a0\u00a0The applicants further emphasised that the tax at issue had not been levied on expropriation compensation awarded following a lawful dispossession but, rather, on an award of compensation for pecuniary and non-pecuniary damage for a deprivation of property which the domestic courts had recognised as unlawful. They contended that that was the only instance at national level in which an award of compensation could be subject to taxation.<\/p>\n 36.\u00a0\u00a0Lastly, the applicants complained under Article 14 of the Convention that the application of Law no.\u00a0662 of 1996 to their case produced discriminatory effects.<\/p>\n THE LAW<\/strong><\/p>\n 37.\u00a0\u00a0In respect of the above complaints, the applicants relied on Article 1 of Protocol No. 1 to the Convention, which reads as follows:<\/p>\n \u201cEvery natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law.<\/p>\n The preceding provisions shall not, however, in any way impair the right of a State to enforce such laws as it deems necessary to control the use of property in accordance with the general interest or to secure the payment of taxes or other contributions or penalties.\u201d<\/p>\n 38.\u00a0\u00a0The Court notes at the outset that the applicants were deprived of their property by means of an indirect or \u201cconstructive\u201d expropriation, an interference with their right to the peaceful enjoyment of their possessions which the Court has previously considered, in a large number of cases, to be incompatible with the principle of lawfulness, leading to findings of a violation of Article 1 of Protocol No. 1 (see, among many other authorities, Carbonara et Ventura c. Italie, no 24638\/94, \u00a7\u00a7 63-73, CEDH 2000\u2011VI; Guiso-Gallisay v. Italy, no. 58858\/00, \u00a7\u00a7 93-97, 8 December 2005; De Caterina and Others v. Italy, no. 65278\/01, \u00a7\u00a7 30-34, 28 June 2011; and, more recently, Messana v. Italy, no. 26128\/04, \u00a7\u00a7 38-43, 9 February\u00a02017). There are no elements in the case file that would lead the Court to reach a different conclusion in the present case.<\/p>\n 39.\u00a0\u00a0That said, the Court further notes that \u2013 as was also conceded by the applicants \u2013 the Consiglio di Stato acknowledged that the deprivation of property had been unlawful and, by drawing on the Constitutional Court\u2019s judgment no. 349 of 24\u00a0October 2007, held that the applicants were entitled to redress in conformity with the criteria established by the Court\u2019s case-law (see paragraph 23 above). The Court is satisfied that that amounts, in substance, to an acknowledgement by the domestic courts of the infringement complained of. Following the determination, the court awarded an amount equal to the market value of the land at the time they were deprived of their property, increased by an amount reflecting an adjustment for inflation as well as statutory interest from the date that they were deprived of their property. In a similar case, the Court found that an analogous award constituted appropriate and sufficient redress for the breach of Article 1 of Protocol No. 1 suffered by the applicant, and concluded that the applicant could no longer be considered a victim of the violation complained of (see Armando Iannelli v. Italy, no.\u00a024818\/03, \u00a7\u00a7 35-37, 12 February 2013). The Court sees no reason to depart from the approach it adopted in that case. Moreover, the Court points out that in the present case the Consiglio di Stato awarded a further EUR 50,000 for the non-pecuniary damage suffered owing to the unlawful nature of the property deprivation (see paragraph 23 above).<\/p>\n 40.\u00a0\u00a0Nevertheless, the applicants argued that the redress afforded by the Consiglio di Stato, which they do not appear to have complained about per se, was insufficient on account of the tax levied on the amount received. The Court notes that there is no evidence in the case file that, following the raising of the issue at a time when it was premature (see paragraphs 22 and 23 above), the applicants complained about the taxation aspect before the domestic courts once the tax measure had actually been applied. However, it considers that it is not necessary to rule on the issue conclusively because this part of the complaint is in any event inadmissible for the reasons set out below.<\/p>\n 41.\u00a0\u00a0The Court notes at the outset that the impugned tax measure was imposed on the applicants by the Nuoro Municipality under Law no.\u00a0413\/1991, which regulates, inter alia, the collection of taxation on compensation awards for both lawful and unlawful deprivations of property (see paragraphs 30 and 31 above). It would therefore appear to the Court to be the most appropriate approach to examine the applicants\u2019 complaint from the standpoint of a control of the use of property \u201cto secure the payment of taxes\u201d (see National & Provincial Building Society, Leeds Permanent Building Society and Yorkshire Building Society v. the United Kingdom, 23\u00a0October 1997, \u00a7 79, Reports of Judgments and Decisions 1997\u2011VII). In the Court\u2019s view, therefore, the levying of taxation in the present case ought not to be considered against the backdrop of the redress afforded for the deprivation of property but, rather, under the second paragraph of Article 1 of Protocol No. 1.<\/p>\n 42.\u00a0\u00a0According to the Court\u2019s well-established case-law (see, among many other authorities, Gasus Dosier- und F\u00f6rdertechnik GmbH v. the Netherlands, 23 February 1995, \u00a7 62, Series A no. 306\u2011B,and N.K.M. v.\u00a0Hungary, no. 66529\/11, \u00a7 42, 14 May 2013), an interference, including one resulting from a measure to secure the payment of taxes, must strike a \u201cfair balance\u201d between the demands of the general interest of the community and the requirements of the protection of the individual\u2019s fundamental rights. The concern to achieve this balance is reflected in the structure of Article 1 as a whole, including the second paragraph: there must therefore be a reasonable relationship of proportionality between the means employed and the aims pursued. Lastly, applicants must not bear an individual and excessive burden (see Sporrong and L\u00f6nnroth v. Sweden, 23\u00a0September\u00a01982, \u00a7 73, Series A no. 52).<\/p>\n 43.\u00a0\u00a0Furthermore, in determining whether this requirement has been met, it is recognised that a Contracting State, not least when framing and implementing policies in the area of taxation, enjoys a wide margin of appreciation and the Court has consistently held that it will respect the legislature\u2019s assessment in such matters unless it is devoid of reasonable foundation (see Gasus Dosier- und F\u00f6rdertechnik GmbH, cited above, \u00a7 60, Series A no. 306\u2011B; Imbert de Tr\u00e9miolles v. France (dec.), nos. 25834\/05 and 27815\/05 (joined), 4 January 2008; and Arnaud and Others v. France, nos. 36918\/11 and 5 others, \u00a7 25, 15 January 2015). It is, indeed, primarily for national authorities to decide the type of taxes or contributions they wish to levy, since decisions in this area will commonly involve the appreciation of political, economic and social questions which the Convention leaves within the competence of the States parties, the domestic authorities being better placed than the Court in this connection (see N.K.M. v. Hungary, cited above, \u00a7 57).<\/p>\n 44.\u00a0\u00a0Turning to whether a fair balance has been struck in the case at hand, the Court considers at the outset that it was well within the area of discretionary judgment for the Italian legislature to develop substantive tax rules providing for taxation of capital gains arising from dispossessions of property. Consequently, the legislation cannot be considered to be arbitrary as such (see Di Belmonte v. Italy, no. 72638\/01, \u00a7 42, 16 March 2010, and, mutatis mutandis, Arnaud, cited above, \u00a7 27). Moreover, choices as to the type and amount of tax to be levied, but also, as in this case, the related question as to what may be classified as taxable income, fall within those issues that the domestic legislature is certainly better placed than the Court to assess and determine (see, mutatis mutandis, G\u00e1ll v. Hungary, no.\u00a049570\/11, \u00a7 56, 25 June 2013; Bal\u00e1\u017e v. Slovakia (dec.), no. 60243\/00, 16\u00a0September 2003; and Spampinato v. Italy (dec.), no. 69872\/01, 29\u00a0March\u00a02007). The Court finds that the same can be said as regards the choice as to the concrete means of enforcement, namely deduction at source, with the option left to the taxpayer to choose the regular taxation route. In view of the foregoing, the Court considers that the respondent State should be afforded a particularly wide margin of appreciation in the present case.<\/p>\n 45.\u00a0\u00a0It remains to be ascertained whether the impugned fiscal measure could be viewed as having imposed an unreasonable or disproportionate burden on the applicants.<\/p>\n 46.\u00a0\u00a0The Court considers at the outset that the tax rate applied in the present case, which amounted to 20% of the total compensation awarded, cannot be considered, from a quantitative standpoint, as prohibitive. Moreover, it cannot be said that the deduction of such an amount had the effect of nullifying or essentially frustrating the award of compensation made by the Consiglio di Stato, to the extent of causing the tax burden to acquire a \u201cconfiscatory\u201d nature. Nor did it lead to a paradoxical situation whereby the State took away with one hand \u2013 in this case in taxation \u2013 more than it awarded with the other as compensation for a deprivation of property (see, mutatis mutandis, in the context of the application of court fees, Perdig\u00e3o v. Portugal [GC], no. 24768\/06, \u00a7 72, 16 November 2010). The Court is, in other words, satisfied that the fiscal measures applied in the present case did not go as far as to impair the very substance of the applicants\u2019 property rights.<\/p>\n 47.\u00a0\u00a0The Court also notes that there is no evidence in the case file \u2013 and in any event it is not argued by the applicants \u2013 that the levying of such a sum fundamentally undermined their financial situation. This is one of the factors which the Court has given weight to when gauging whether a fair balance has been struck in a given case (see, N.K.M. v. Hungary, cited above, \u00a7 42, and the further references cited therein).<\/p>\n 48.\u00a0\u00a0In its assessment, the Court has also taken into consideration the nature of the sum that was subject to tax and what purpose it served (ibid., \u00a7\u00a068). In the present case, the purpose of the award was to provide redress for an unlawful act of the administration. In that context, the applicants argued that, given the unlawfulness of the expropriation (see paragraphs 14-16 above), they should be exempted from any tax in the same manner as applicants in the procedure before the Court.<\/p>\n It is true that the Court may \u2013 and often does \u2013 exempt sums which it awards under Article 41 of the Convention from taxation in certain cases. The underlying reason is to prevent the respondent State from clawing back part, or even all, of the award made by the Court. The granting of such an exemption is not, however, automatic. In particular, where awards are made to compensate for loss of earnings or commercial profits, which would ordinarily have been taxable, it may not be appropriate to exempt them from taxation (see, for example, Heldenburg v. the Czech Republic (just satisfaction), no. 65546\/09, 9 February 2017, concerning rental income). The Court decides in each case whether or not an exemption is appropriate (see, for example, Visti\u0146\u0161 and Perepjolkins v. Latvia (just satisfaction) [GC], no. 71243\/01, \u00a7 43, ECHR 2014).<\/p>\n The present case concerns a tax provided for by domestic legislation and levied at the domestic level. The tax exemption clause in the Court\u2019s judgments which, as explained above, applies to just satisfaction awards under Article 41 of the Convention if appropriate, cannot be considered applicable by mere analogy to domestic awards, even if those awards serve a similar purpose. Moreover, the Court would draw attention to the fact that the domestic courts recognised that the deprivation of the applicants\u2019 property had not been in accordance with the law and awarded EUR 50,000 to compensate them for the non-pecuniary damage suffered due to the unlawful nature of the dispossession of their land.<\/p>\n 49.\u00a0\u00a0Lastly, the Court finds it relevant to point out that the applicants had the choice under the legislation under scrutiny to opt for taxation under the ordinary income tax regime if they so wished, as taxpayers can choose between accepting the 20% deduction applied to the sum obtained, or opt for ordinary taxation, which determines the amount due as tax taking into account the capital gains in combination with other components of their income (see paragraph 31 above).<\/p>\n 50.\u00a0\u00a0In view of the foregoing, and taking into account the wide margin of appreciation which the States have in taxation matters, the Court considers that the levying of the tax on the compensation awarded to the applicants did not upset the balance which must be struck between the protection of the applicants\u2019 rights and the public interest in securing the payment of taxes.<\/p>\n 51.\u00a0\u00a0Accordingly, this complaint is manifestly ill-founded and must be rejected in accordance with Article 35 \u00a7\u00a7 3 (a) and 4 of the Convention.<\/p>\n 52.\u00a0\u00a0As to the complaint under Article 14, in the light of all the material in its possession, and in so far as the matters complained of are within its competence, the Court considers that the present case does not disclose any appearance of a violation of the above-mentioned Article of the Convention.<\/p>\n 53.\u00a0\u00a0It follows that this complaint is manifestly ill-founded and must be rejected in accordance with Article 35 \u00a7\u00a7 3 (a) and 4 of the Convention.<\/p>\n For these reasons, the Court, unanimously,<\/p>\n Declares the application inadmissible.<\/p>\n Done in English and notified in writing on 8 February 2018.<\/p>\n Abel Campos\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Linos-Alexandre Sicilianos
\nRegistrar\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 President<\/p>\n