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the functions performed by each of the participants in the transaction or series, based on their actual conduct, taking into account
the functions performed by each of the participants in the transaction or series, based on their actual conduct, taking into account
the functions performed, the property used or contributed and the risks assumed, in respect of the transaction, by the participants in the transaction,
the functions performed, the property used or contributed and the risks assumed, in respect of the transaction, by the participants in the transaction,