AUDIT OF THE GAS, PETROLEUM, AND OIL SECTORS

INTRODUCTION:

Environmental Auditing is a feature of good environmental management practice throughout

much of the petroleum industry along with the chemical industry. Oil and Gas industry is one of
the vital industries in the world, largely because of its strategic role in every economy and the
world, at large. The distinctive features that characterized the industry are derived from the
nature of crude oil, its operations and commercial arrangements. This report analyzes the
importance of the hydrocarbon sector in Bolivia. 

The oil and gas sector currently represents a vital component of the Bolivian economy,
accounting for 7 percent of the GDP in terms of production and more than 30 percent of total
government income. In addition, the hydrocarbon sector not only represents an important
economic sector but also a political and social instrument for negotiations, mobilization and
social participation.

In 1996, Law 1689, a new hydrocarbon law, was created to regulate and normalize the
hydrocarbon activities in the country, adjusting the production and management of the oil and
gas sector to the new political reforms that follow an economic liberalization. Until that year, the
state oil company, YPFB (Yacimientos Petroliferos Fiscales Bolivianos) had all the rights to
explore, extract, industrialize and commercialize natural gas and oil in Bolivia, and after that
year, progressively YPFB became a regulator of the sector rather than an active participant on
the sector production and commercialization. Since then, the Hydrocarbons Law was subject of
many debates about the distribution of the benefits of gas and oil, and the potential favoritism
with the Hydrocarbon Law toward transnational corporations. However, Law 1689 and
subsequent foreign investment allowed the discovery of significant reserves of natural gas in
southern Bolivia.

In May 2005, the Bolivia government passed Law 3058, a new version of the Hydrocarbon Law,
repealing the former Law 1689. The new law was to ensure a more equitable distribution of the
benefits of gas and oil and gain control of the production chain of the hydrocarbon sector by the
state. However, in June, 2005, due to the growing social crisis and the popular demand for a
complete nationalization of the oil and gas sector, Carlos de Meza Gisbert had to abdicate the
office and Eduardo Rodriguez Veltze, his successor in the office, a transitional government,
called for new presidential elections.

In May 2006, the newly elected president, Evo Morales Ayma, who is considered the first
indigenous president in Bolivia, placed the Bolivian hydrocarbon sector under state control by
passing the Supreme Decree3 of Nationalization 28701. The decree obliges all transnational and
international companies to return to the state, through YPFB.

Under this decree of nationalization, companies had a 180-day transition period to renegotiate
and sign new contracts with YPFB if they want to operate in Bolivia. At the same time, the new
president also guaranteed that this nationalization process would not take on the form of

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expropriation or confiscation of facilities, but clearly stated that “Bolivia wants partners in
business not bosses.” (Evo Morales’ speech to the United Nations, September 22, 2006) 

TAX STRUCTURE OF THE HYDROCARBON PRODUCTION CHAIN

According to Article 31 of Law N 3058, the hydrocarbon activities are classified as follows:
UPSTREAM ACTIVITIES
Exploration and Exploitation
DOWNSTREAM ACTIVITIES
a.) Refining and Industrialization
b.) Transportation and Storage
c.) Commercialization
d.) Distribution of Natural Gas through Networks
According to the provisions of Law N 843 and regulatory standards, individual corporations will
be subject to the following general tax system:

 Value Added Tax(VAT)

 Transactions Tax(TT)
 Company Profit Tax (CPT)
 Company Profit Tax- Beneficiaries from abroad(CPT-BA)
Those who devote themselves to the hydrocarbon business and considering the economic
activity, in addition to the taxes indicated in the previous paragraph will be subject to the
following taxes:

 Special Tax on Hydrocarbons and their By-products(STHC)

 Direct Tax on Hydrocarbons(DTH)
The entire chain is subject to the general taxation system taxes with exemptions, as well as to the
specific ones of the sector
TAXES ON HYDROCARBON SECTOR ACCORDING TO PHASE OF OPERATION AND
ACTIVITY

PHASE ACTIVITIES TAXES OF A SPECIFIC

GENERAL ACTIVITIES
NATURE
UPSTREAM Exploration VAT, TT, CPT,
Exploitation CPT-BA(1)
DOWNSTREA Refining and Industrialization VAT, TT, CPT, STHC(2)
M Transportation and Storage CPT-BA(1)
Commercialization STHC(2), DTH(3)
Distribution of Natural Gas

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(1)The CPT-BA is only applicable in case of remittances abroad.
(2)The STHC is applied to wholesale import and commercialization in the internal market.
(3)YPFB, the state enterprise is subject to this tax through the fulfillment of the generating event
established when measuring the production of hydrocarbons in its first stage of
commercialization at the examination point, in accordance with article 54 of Law N 3058.
TAXES OF THE HYDROCARBON SECTOR ACCORDING TO STRUCTURE
Tax Rate Tax Base Exemption Regulation

VAT- Value Added Tax 13% Invoice sales less purchases related to - Law N 843, Articles 1 to 4 and 15
taxed activity

TT- Transactions Tax 3% Gross Revenues The purchase of hydrocarbons Law N 843, Articles 72 to 75
intended for export

CPT- Company Profit 25% Net Profit on Financial Statements Industrialization operations free from Law N 843, Articles 36 to 39 to 50
Tax payment for a period of 8 years

CPT-BA- Company 25% 50% of presumptive profit - Law N 843, Article 51

Profit Tax- Beneficiaries
from abroad

DTH- Direct Tax on 32% Production of hydrocarbons Volumes of gas intended for social Law N 3058, Article 53 to 57
Hydrocarbons throughout the national territory and productive use of natural gas in
the internal market

STHC- Special Tax on Specific rate per of Import and commercialization of - Law N 843 Article 108 to 114
Hydrocarbons and their petroleum-derived hydrocarbons and their by-products in
By-products product the internal market

GENERAL EXAMINATION PROCEDURE

TAX AUDIT - is a systematic verification process or formal examination conducted by the
IRS to verify information or uncover inaccurate tax returns or fraud. The IRS selects tax
returns to examine both randomly and based on apparent irregularities in the returns that
have raised questions. Its purpose is to determine whether the accounting standards have
been correctly applied, if the tax legal regulations have been correctly interpreted and
applied if, accordingly, the taxpayer returns have been adequately prepared.

Examination procedure - an administrative process which establishes the efficient

different and timely beginning and conclusion of the assessment processes in their
modalities, according to Law Nº 2492 of the Bolivian Tax Code.

Article 100 of the Bolivian Tax Code in keeping with the Article 66 of the Bolivian Tax
Code - stipulated regards to tax control, checking, verification, audits, examination and
investigation counts on the following examination process modalities, “Grants extensive powers
to the Tax Administration for those purposes, including authority to request information from
other domestic and foreign tax authorities, companies, and institutions, as well as international
agencies.”

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 Transparency of the Regulatory System
Article 66 of the Commercial Code (Law 14379, 1977) - states that unfair competition, such as
maintaining an import, production, or distribution monopoly, should be penalized according to
criminal law.  There are no informal regulatory processes managed by nongovernmental
organizations or private sector associations.
EXAMINATION PROCESS MODALITIES

Audit Processes
Total Inspection Partial Inspection
Review of all taxes that reach the taxpayer of Review of certain taxes of one or more fiscal periods
at least one management
External Verification Internal Verification
Timely review of elements, facts, economic Massive revision from observations generated by
transactions of one or more taxes or fiscal cross-checking of information from the Tax
periods, including tax refund audits Administration databases
To carry out an examination, there is a standard procedure whose examination order, assignment
of officials, documentation request, verification and analysis will vary according to the modality
applied, as shown below:

 Preparation of tax intelligence studies for identifying possible examinations.

 Generation of examination order, following acceptance of the request for
examination order report an assignment of officials.
Audit procedures – an important area of the syllabus, though candidates often use inappropriate
audit procedures to answer questions
Every procedure must state:

 the assertion tested

 the audit procedure
 the reason for the procedure
After the identification of the sector, item and taxpayer, the Examination Department will
proceed with the following schedule:
a) Issuance of Examination or Verification Order.
b) Notification to the taxpayer along with the Order, including the Request for Information
with deadlines.
c) Receipt of documents requested
d) Verification and analysis of documents (Office review and/or Field Work).
e) Determination of results and objections raised.
f) Preparation of reports
 Issuance of Report and Assessment Resolution for Nonexistence of Tax Debt on not
finding objections or total payment (omitted tax, interest, fines and sanction, if
appropriate).
 Issuance of Report and Intervention Resolution in case payment of the debt were
omitted or partially made.
g) Notification to the taxpayer with the Intervention Resolution.

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 h) The taxpayer has a thirty (30) day inextensible term as of the day of the notification of
the Intervention Resolution to pay or submit the objections he may deem convenient.
i) Following that Term, the Assessment Resolution is issued and the latter becomes the Tax
Execution document which is notified to the taxpayer.

STRATEGIC ANALYSIS OF THE SECTOR

Taxpayer History
 Analysis of information dealing with taxes and others which includes background on:
 taxpayer’s behavior
 financial statements and F 605 of EEE presentations
 previous audits by SIN and internal auditors
 annual report
 information from stock exchange
 minutes of the board of directors
 operational organization chart
 monthly details of the general ledger
 monthly journal
 legal files
 agreements and contracts
Customer's business and industry

 Description of the industry

 Investments
 Risk
 Regulations
 Profitability
 taxes applied to the sector
 relationships and government policies that could affect it
Information of the company and related companies

Is it a branch, parent company, belongs to some holding?

What is its share of the stock?
Legal representatives?
What is its activity?
 When did it begin?
Comparative analysis of balance sheet stories

 Review of variations in each account

 Identifying unusual and/or significant adjustments
 Identification of noncompliance with requisites

Assessment of risk of non-conformity

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  Allocation of exploration expenses
 correct classification of deductible expenses and costs which may be capitalized
 cash calls (allocation of resources)
 billing (accountability)
 review of revenues not subject to CPT
 review of expenses and foreign staff costs
 treatment of losses and profits, accounting and tax depreciation method
 Allocation of noncompliance and requisites.
Identification of industry risk factors

 Obtaining an understanding of the company and its environment

 Obtaining an understanding of internal control over financial reporting
 Considering information from the client acceptance and retention evaluation, audit
planning activities, past audits, and other engagements performed for the company
 Performing analytical procedures
 Conducting a discussion among engagement team members regarding the risks of
material misstatement; and
 Inquiring of the audit committee, management, and others within the company about the
risks of material misstatement.
Selection of subjects for examination for the audit
The following criteria:
Materiality: Does the activity or program have potentially significant financial, economic,
social or environmental management implications?
Impact: Is an audit likely to have a positive impact on the community? Could it lead to
improvements across the public sector in efficiency, effectiveness or accountability? Would an
audit address concern within entity?
Risk: Are there any indicators of known or suspected problems? Has the program changed
significantly or undergone sudden expansion? Are issues emerging in related areas that could
affect the area being considered for audit? Are there inherent risks that may not be well
managed? Would any problems result in adverse consequences?
Context: Is there strong community interest in the topic? Does the program have high political
sensitivity or national importance? Is it the right time to review this area? Are issues already well
known? Is there another review or audit in progress covering similar issues? Would an audit of
the area reinforce other important current messages or themes?
Coverage: Have we audited this area or entity recently? Does the topic help meet our objective
of providing a balanced coverage of government portfolios and performance over time?
Auditability/efficiency: Is the area amenable to audit? Will information and evidence be
available? Can a past methodology be used or will the methodology be reusable? Can analytical
tools be used? Can it be audited with resources that match the impact and materiality of the topic
or will it take disproportionate resources for limited benefit?

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4. Tax Auditing of Hydrocarbons Sector
The primary duty in auditing of the hydrocarbons sector, in the case of YPFB, a Bolivian Oil
Company, is the receipt and payment of amounts pertaining to DTH or Downstream operations,
conciliations and rectifications arising from contracts undertaken, all these on top of other
internal regulations that bounds the company. Audits are performed throughout the process,
beginning in the production stage to guide the quality and accuracy of amounts.
Careful undertaking of audit is achieved through following established and systematic processes.
Auditing in the production stage constitutes comparison of amounts that translates to qualitative
information produced by the examination. Subsequently, these amounts of DTH that pertain to
obligations should be paid according to the terms of the Contracts of Operation. Lastly,
verification of the annexes of the tax payments that subjects the production of YPFB’s
petroleum, natural gas and PLG of plants should be strictly observed. There are several taxes
applied to the Hydrocarbon sector in accordance with Bolivian Legislation. Direct and indirect
national taxation is applied. Currently, there are four (4) national taxes that applies; Value Added
Tax (IVA), Complementary Regime of the
Added Value Tax (RC-IVA), Tax to Transactions (IT), and Tax to the Enterprise Profits
(IUE.)

It is of utmost importance to establish strong audit mechanisms and institutions to oversee,

control and monitor on a procedural manner the financial movements and balance sheets of
transnational companies operating in Bolivia. The company shall accurately report its profits and
other financial information so the government can audit these financings capably.

4.1 Audits of Upstream Operations

Upstream Operations of the Hydrocarbon sector pertain to activities of hydrocarbon exploration,
drilling and production in Bolivia. For YPFB, this involves the production of outputs of
petroleum, natural gas and PGL from plants. This segment also covers the exploitation up to its
delivery in the refinery, processing or cracking plants before undergoing industrial processes.
Taxes apply during Upstream Operations; namely VAT, TT and CPT.
During the Tax Audit process, the main tax generating event is assessed. This analysis is
completed at examination point. Following this, the main objective is cross-checking of revenue
received if it coincides with the price and the amount produced. This process is important
because it is a source of profit for the reconstruction of productive process techniques which
requires input and use of fixed assets.
Consequently, both technical and legal standards are followed in the petroleum sector’s
accounting records. Techniques applied in accounting and tax verification activities of Upstream
operations are for VAT, TT and CPT.
This section is introducing another source of income of the hydrocarbon sector in the
country that is not related to any production activity.
For Value Added Tax (VAT)

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1. Review of the holder’s compensation which consists of the recovery of costs that includes
labor, materials, depreciation, and others.
2. Review of the documents related to the production of petroleum and gas.
3. Review of purchases and make sure that are related to the taxed activity, complied with the
formalities, and supported with reliable means of payment according to the rules.
4. Compare purchases and sales with third-party informants.
For the Tax to Transactions (TT)
1. Compare the amount sold in the internal market with the produced amount to recognize
reported revenues.
For the CPT

1. Compare the amount sold in the internal and/or external market with the amount produced, to
identify undeclared revenues.

2. Identification of accounting errors such as non-deferral of an expense, undue allocations, and

depreciation of fixed assets according to the specific tax standards, which generates expense.

3. Identification of operations excluded from accounting process; for instance, the simulation of
losses and liabilities along with the concealment of profits and assets (accounts receivable).

4. Review of the holder’s compensation consisting recovery of costs, which includes labor,
materials, and depreciation of fixed assets, among others.

5. Review of deductible and nondeductible expenses for the determination of the tax base.

4.2. Audits of Downstream operations

Using tax intelligence study, the scope of the tax audit is determined. It contains taxes, periods
and items to be reviewed according to the modalities established under item 3.

In Downstream operations the following activities must be assessed:

a. Refining and Industrialization;
b. Transportation and Storage;
c. Commercialization;
d. Distribution of Natural Gas through Networks

4.2.1 Refining
Refining is a process that transforms petroleum into products called carburants, liquid or gas
fuels, lubricant, grease, paraffin, asphalt, solvents and other sub products.
Refineries can review the following taxes according to specific procedures: VAT, TT, CPT,
CPT-BA, RC-VAT and STHC.
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4.2.2 Retail commercialization
It covers service station activities and sale of lubricants, of products and other sub products
derived from petroleum to the end customer.
The following taxes are reviewed in this activity according to specific procedures: VA, TT, CPT,
CPT-BA, and RC-VAT.
4.2.3 Transportation of Hydrocarbons
Transportation of Hydrocarbons is the activity of transferring hydrocarbon or their-by products
by the use of various means such as pipes or pipelines. In transporting hydrocarbons, it is
important to ensure its necessary storage to prevent wastage and any hazards. The distribution of
natural gas through various networks is excluded in this activity. The following taxes may be
examined in the transportation of hydrocarbons: Value-Added Tax (VAT), Transfer Tax (TT),
Company Profit Tax (CPT), Company Profit Tax – Beneficiaries from Abroad (CPT-BA), RC-
VAT, according to specific procedures for each of them.
4.2.4 Some additional techniques for downstream view
In the case of STHC one verifies:
1. If the tax was paid upon leaving the refinery.
2. Types and amounts of product whether refined or not based on reports submitted
3. Consistency of amounts purchased and amount refined
4. Turnover of the products refined and sold
5. Amount imported and taxes paid
In the case of VAT one verifies:
1. Number of sales invoiced and reported to authorities considering the volumes
purchased and transported.
2. The invoiced conform to the period of commercialization and/or measurement
(continuous services)
3. Number of purchases which comply with the formalities and have supporting reliable
means of payment according to the regulations.
4. Compare the purchases and sales with third-party informants
5. Tax debit and tax credit of the purchaser:
a. STHC is shown separately in the invoice. Seller pays the tax debit on the total
price, without considering the STHC.
b. VAT Tax Credit is calculated based on the total of the invoice issued by the
refinery (including the ISTHC).
In the case of TT one verifies:
1. If the tax rate is applied on the margin (sales less purchases).

In the case of CPT one verifies:

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 1. Taxable and nontaxable revenues declared by the taxpayer
2. Expenses supported by documents which shows compliance to tax regulations.
3. Bank transactions for sending remittances abroad and their corresponding
withholding of CPT-BA.
CASES
Case 1: Invoices with taxation events from other period
Servicios Bolivia issues invoices supporting tax credit on a production company last October 24,
2002 and March 7, 2003 on a taxable event from previous period, the invoices were related to the
leasing of cryogenic facility, as well as cost of imports paid to Services Company (a company in
USA) through bank transfer but without withholding the profit tax (CPT) for beneficiaries
abroad. Payment of the transaction was supported by international invoices. It was then audited
after analyzing the situation and in order to obtain tax advantages it was then decided that
Services Company should return bills and replace them with local invoices to Bolivia Services.
In addition to the taxpayer mentions that the taxation event for services is created at the time of
their delivery, (1) the observed invoices relate to a service that at the date of invoicing was in
progress and which execution had not been completed, (2) Although there was a partial payment
of the price, the supplier did not invoice in due time. The taxpayer argues that the amounts paid
to the company “Services Company” are for services that were in progress at that time. In this
regard, they note that the service referred to was a financial leasing contract and payments for the
importation of equipment; therefore under the tax legislation for financial lease, the taxable event
is completed at the due date of each installment. Therefore, it is not that production company,
four years later, in an attempt to address its lack of withholding tax sui-BE at the time, take a tax
credit by a fact that originally according to the background was having made withholding sui
beneficiaries from the outside. In this respect the Supreme Decree They shall withhold and pay
until the fifteenth day (15) of the month following the one in which there taxable facts took
place, the aliquot general of the tax on the taxable net income equivalent to fifty percent (50%)
of the total amount paid, credited, or delivered.
Regarding the present concept, the departmental Court of Justice of Santa Cruz has at first
instance in favor of the tax administration, and a final decision from the of the Supreme Court is
pending
Case 2: Overhead incomes not invoiced

In the review of accounting records and supporting documents, it was found out that Enterprise
oil received revenues without issuing any invoice. The respective invoices for reported bank
accounts were not issued for “expenses for the beneficiary oil block” and “income actually
received by the services provided to members by the operators” in spite of having an
accounting manual.
According to the accounting procedures manual of the taxpayer accounts operations, the
income account “OVERHEADS RECOVERY AGREEMENTS” shall be paid by the amount of
the overheads invoiced to the partners and charged to the checking accounts. In the case of
services delivered, income corresponding to the overheads was received. The cash received by
the taxpayer Oil company represent revenue taxed by value added tax and transaction tax.
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According to the taxpayer, the revenue represents the accounting for reimbursement that
partners make to the oil operator and do not correspond to any service, therefore does not
reflect in his billing.
Meanwhile, account 75.903.100 was incorrectly interpreted as OVERHEAD RECOVERY
ACCORDING TO AGREEMENTS. Regardless of the text that goes with it, shows its essential
feature, and, more importantly, is consistent with the economic reality of operations that are
none other than REIMBURSEMENTS for expenses incurred by the company as operator
regarding the oil administration. As stated, the tax payer argued that revenues from
reimbursements are not taxable income because they are not included in the object of the VAT,
and are expressly excluded from the object of the tax to the transaction.
As indicated, the company as operator of a risk-sharing agreement does not provide service to
the holding or the other partners. The objective of the operator is to generate profits to be
distributed to all shareholders, by which, non-operating partners refund all of the administrative
and operational costs. In the case of Transaction Tax, it includes in the national territory, trade,
industry, profession, business, rental, and goods of works and services or any activity, whatever
the nature of the subject that lends.
The following are established from the analysis and assessment of the taxpayer:
It was indicated that some accounts does not correspond to any income but represent the
reimbursement of partners to the oil operator. They explained that the installment in the bank
accounts come from the transfer of funds from each of the holdings. The holding accounts
represent expenses and oil company accounts represent the income (cash paid). The funds
received by the oil company represent income since they are fund transfers delivered by each of
the partners to the oil company.
The taxpayer does not present any documentation to support the expenditures made and
registered on the account. However, he believes to be entitled to reimbursement, when the
expenses incurred by the subsidiaries operated by the oil company were already registered and
appropriate to different spending accounts. The taxpayer claims that the overheads represent
REIMBURSEMENTS for expenses incurred; however, the absence of documentation
demonstrates the delivery of administrative services by the operator to the oil holding.

The account of the overhead operator that registers the expenses has been considered deductible
for purposes of the CP. This case was discussed by the Tax Superintendence and that two
instances have ruled in favor of the tax administration, the case being currently analyzed by the
Supreme Court of Justice.
Case 3: Payments made for services received from Headquarters

The review conducted by the Tax Administration Unit of the Ministry of Finance revealed that
the expenses identified in the ledgers of X-Bolivia were not included in the calculation of the
CPT-BE withholding. The taxpayer states that since the payments are made to a company
domiciled abroad, the withholding should be made under the Bolivian tax law. However, since
the company is not a Bolivian entity, the mandatory application of the convention is required.
The first step in implementing a DTC is to identify who are the parties to which the treaty
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applies. In most cases, the answer is as follows: persons who are residents of both Contracting
States. It is also necessary to prove that the company X-Bolavia is registered in Bolivia. This
means that the entity has been established in Europe and is entitled to the DTC. DTC signed
between Bolivia and European country can help companies avoid double taxation. The DTC
generally favors the residence principle when it comes to taxation of companies. For instance, if
a company gets revenue in a country where it is not registered, then its profits will be taxed in
that country. Generally, if a European company gets revenues from Bolivia, this should be taxed
in the European country. However, if the company operates through a permanent establishment
in Bolivia, this should not be considered as taxation in Bolivia.

Conclusions:

The analysis of the Bolivian hydrocarbon sector from historical, social and economic
perspectives shows that without doubts, Bolivia highly depends on the revenues from the sector.
The report concludes that the nationalization of the hydrocarbon sector was indeed a necessary
measure that had significant reasons for the country in order to reverse the unfavorable share of
revenues that progressively declined from almost 50 percent to 18 percent of the production.

With the experience gained in the implementation of control processes, we can ensure that audits
results have improved substantially, providing higher revenues, as well as better legal,
accounting and technical support in the observations made. Due to the high number of
transactions from companies domiciled in the country with foreign companies, whether
headquarters, subsidiaries, etc., we are currently working on amendments to the tax legislation,
to make this more practical and appropriate in the development of audits to the oil companies.
Due to the expansion of the transnational corporations operating in the oil industry, with foreign
companies, either unrelated or related parties, the control of companies that perform this type of
transactions, the increase of operations with foreign partners and the transfers costs, one of the
main challenges for the Administration today is the control of companies performing this type of
transactions.

References:

·         file:///C:/Users/user/Downloads/inesad-wp2007-06.pdf

·         https://www.academia.edu/8904433/ACC_8211_Oil_and_Gas_Accounting_?
fbclid=IwAR2c2qjELksenxUV6qclxbl9rRIkTRnGXY-mabqnSTMGGa-PJd-csSuLtaw

·         https://www.environmentalpollution.in/industrial-pollution/effective-environmental-
auditing-in-the-petroleum-industry/2615?
fbclid=IwAR3w_EMa3yRxIHoUNCbNZGi1RbGYN9w30aqb2zJn5pXoYAzkmJbJbDURzz0

Banderado – Bito-onon –Bolivar – Cabalonga – Cadiao – Calde – Chavez – Delos Santos – Deploma –
Deslate, Elaine – Deslate, Hannah – Espada – Guillen – Javier – Mijares – Monsale – Mustuddi – Salazar
– Santisteban – Sequite –Servandil – Taliseo – Tambalo –– Tapan ––Torrechante