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Audit in New Zealand vs France: Key Differences

Audit in New Zealand

Understanding the differences in audit requirements is essential for any multinational business seeking compliance, transparency, and investor confidence. In this blog we compare the auditing requirements in New Zealand and France. Regulatory Bodies and Audit Frameworks Both France and New Zealand have well-established regulatory systems that ensure the integrity and transparency of financial reporting. Company Audit in France In France, the audit profession is regulated by the Haut Conseil du Commissariat aux Comptes (H3C), which ensures the quality and independence of auditors. Audits are performed in accordance with the Normes d’Exercice Professionnel (NEP), developed under the authority of the H3C. As France operates under a civil law system, audit obligations and professional standards are clearly defined and codified in legislation. Company Audit in New Zealand In New Zealand, the Financial Markets Authority (FMA) oversees the audit profession and enforces compliance with national auditing requirements. Auditors follow the New Zealand Auditing and Assurance Standards (NZ ASAs), which are aligned with the International Standards on Auditing (ISA) and issued by the External Reporting Board (XRB). Unlike France, New Zealand operates under a common law system, which places strong emphasis on principles-based regulation, professional judgement, and transparent corporate governance practices. Despite these differences, both frameworks aim to promote transparency, reliability, and trust in financial information. Auditing Process In both France and New Zealand, the purpose of auditing is the same: to verify the accuracy of financial statements, ensure transparency, and strengthen confidence in a company’s financial reporting. This means that auditors in both countries focus on confirming that the financial statements present a true and fair view of the company’s financial position in accordance with the respective national auditing standards. Throughout the audit process, they are also required to remain fully independent and objective to maintain the integrity of their opinion. Both jurisdictions also require auditors to report any irregularities they identify during their work, although the approach differs. In France, auditors have a formal procédure d’alerte (alert procedure), which obliges them to inform the company’s management and, if necessary, the commercial court when they detect irregularities that could threaten the company’s going concern. In New Zealand, there is no structured alert procedure equivalent to France’s system. Instead, auditors must comply with statutory reporting obligations under the Financial Markets Conduct Act 2013 and related regulations. This includes reporting serious wrongdoing, breaches of financial reporting requirements, and concerns about auditor independence to the appropriate authorities such as the Financial Markets Authority (FMA) or, in some cases, the company’s shareholders. Additionally, French auditors play a broader role beyond the annual audit of financial statements. They may be appointed to perform specific assignments such as verifying the value of contributions during mergers, transformations, or capital increases. Statutory Audit Requirements Thresholds Criteria France New Zealand Audit Requirement Trigger Mandatory if company exceeds 2 of 3 thresholds: • Balance sheet total: €5 million • Turnover (excl. VAT): €10 million • Employees: >50 Proprietary company considered “large” if they meet (Companies Act 1993) meeting either of the following for the two preceding years: • Total assets ≥ NZD 66 million, or • Total revenue ≥ NZD 33 million, or • 1 or more large subsidiaries Audit Obligation Large and medium-sized companies must appoint a statutory auditor (commissaire aux comptes). • FMC reporting entities must have financial statements audited by a licensed auditor. • Large companies (NZ or overseas) must prepare audited financial statements. Lower Thresholds for Subsidiaries Applies when controlled by an entity already audited: • Balance sheet: €2.5 million • Turnover: €5 million • Employees: >25 For overseas companies with subsidiary in New Zealand meeting either of the following for the two preceding years: • Total assets ≥ NZD 22 million, or • Total revenue ≥ NZD 11 million Other Entities that need to conduct an Audit Non Profits are required if annual donations + subsidies exceed €153,000 or if recognized as public utility, issue bonds, or provide microloans. • Charities that spend over NZ$1.88 million for two years in a row must get a full audit from a qualified auditor. • If your charity spends between NZ$938,085.65 and NZ$1.88 million, you can pick either an audit or a review. • Non Profits must conduct an audit if they have annual operating expenses of NZD $500,000 or more or if they receive government funding of NZD $10,000 or more. Public Companies All public limited companies (Société Anonyme – SA) require audits regardless of size. All listed companies need to prepare financial reports. Filing / Submission Timeline Financial statements filed annually with the Greffe du Tribunal de Commerce. Financial statements must be filed or lodged no later than: • 4 months from the balance date for FMC reporting entities, and • 5 months from the balance date for large companies. You can read more about audit requirements in France on our dedicated blog post. Auditor Appointment Appointment of an Auditor in France In France, a statutory auditor (commissaire aux comptes) can be appointed either directly in the company’s founding documents (statuts) or later by a resolution passed at a general shareholders’ meeting. If an auditor has not been appointed or a vacancy arises due to resignation or dispute, the commercial court may designate one to ensure compliance with audit obligations. Compliance with the audit law in France requires companies to appoint both a principal (titular) auditor and an alternate auditor, who steps in if the primary auditor is unable to perform their duties. Auditors must be selected from the official registry maintained by the Haut Conseil du Commissariat aux Comptes (H3C). Rotation rules: Public Interest Entities (PIEs) are required to change their audit firms every 10 years. This rotation period can be extended up to 24 years if the audit firm is appointed through a competitive tender process, ensuring that companies periodically reassess and select their auditors transparently. For companies that are not classified as PIEs, auditors are typically appointed for a term of 6 years, but there is no strict requirement for mandatory rotation. You can read

Audit Requirements in Singapore vs France: Key Differences

Audit Requirements in Singapore

Understanding the differences in audit requirements is essential for any multinational business seeking compliance, transparency, and investor confidence. In this blog we compare the auditing requirements in Singapore and France. Regulatory Bodies and Audit Frameworks Both France and Singapore have well-established regulatory systems that ensure the integrity and transparency of financial reporting. Auditing in France In France, the audit profession is regulated by the Haut Conseil du Commissariat aux Comptes (H3C), which ensures the quality and independence of auditors. Audits are performed in accordance with the Normes d’Exercice Professionnel (NEP), developed under the authority of the H3C. As France operates under a civil law system, audit obligations and professional standards are clearly defined and codified in legislation. Auditing in Singapore In Singapore, the Accounting and Corporate Regulatory Authority (ACRA) oversees the audit profession and enforces compliance with national auditing requirements. Auditors follow the Singapore Standards on Auditing (SSAs). Unlike France, Singapore operates under a common law system, placing greater emphasis on principles, professional judgment, and sound corporate governance practices. Despite these differences in auditing requirements, both frameworks aim to promote transparency, reliability, and trust in financial information. Auditing Process In both France and Singapore, the purpose of auditing is the same: to verify the accuracy of financial statements, ensure transparency, and strengthen confidence in a company’s financial reporting. This means that auditors in both countries focus on confirming that the financial statements present a true and fair view of the company’s financial position in accordance with the respective national auditing standards. Throughout the audit process, they are also required to remain fully independent and objective to maintain the integrity of their opinion. Both jurisdictions also require auditors to report any irregularities they identify during their work, although the approach differs. In France, auditors have a formal procédure d’alerte (alert procedure), which obliges them to inform the company’s management and, if necessary, the commercial court when they detect irregularities that could threaten the company’s going concern. Similarly, under the Companies Act, auditors in Singapore are required to report to the Accounting and Corporate Regulatory Authority (ACRA) if they suspect that a company has committed an offence under the Act. This includes instances of fraud or misrepresentation in financial statements. Additionally, French auditors play a broader role beyond the annual audit of financial statements. They may be appointed to perform specific assignments such as verifying the value of contributions during mergers, transformations, or capital increases. Statutory Auditing Requirement Thresholds Criteria France Singapore Audit Requirement Trigger All companies which meet 2 of the 3 conditions below need to do a statutory audit: • Total annual revenue > S$10 million • Total assets > S$10 million • Number of employees > 50 Proprietary company considered “large” if it meets 2 of 3 thresholds: • Revenue: ≥ AUD 50 million • Gross assets: ≥ AUD 25 million • Employees: ≥100 Audit Obligation All companies are required to appoint an auditor unless they are considered a small company, in which case they are exempt. Large proprietary and all public companies must prepare audited financial reports. Small proprietary companies only if directed by ASIC or shareholders. A company is considered a small company if – a. it is a private company in the financial year in question; and b. it meets at least 2 of 3 following criteria for immediate past two consecutive financial years: i. total annual revenue ≤$10m; ii. total assets ≤ $10m; iii. no. of employees ≤ 50 Lower Thresholds for Subsidiaries Applies when controlled by an entity already audited: • Balance sheet: €2.5 million • Turnover: €5 million • Employees: >25 Charities: • Gross income or expenditure > S$500,000 → audited by a public accountant • S$250,000–S$500,000 → examined by a qualified independent person or audited • ≤ S$250,000 → examined by a competent independent person or audited Institutions of a Public Character (IPCs): Audited by a public accountant, regardless of income. Charities as Companies Limited by Guarantee (CLGs): Accounts must be audited, regardless of income. Other Entities that need to conduct an Audit Non Profits are required if annual donations + subsidies exceed €153,000 or if recognized as public utility, issue bonds, or provide microloans. Companies limited by guarantee: • Revenue < AUD 1 million → audit or review • Revenue ≥ AUD 1 million → audit mandatory Public Companies All public limited companies (Société Anonyme – SA) require audits regardless of size. All public companies must prepare audited financial reports and lodge them with the Accounting and Corporate Regulatory Authority (ACRA). Filing / Submission Timeline Financial statements filed annually with the Greffe du Tribunal de Commerce. Annual Return must be filled within 7 months after the end of the company’s financial year. You can read more about audit requirements in France on our dedicated blog post. Auditor Appointment Appointment of an Auditor in France In France, a statutory auditor (commissaire aux comptes) can be appointed either directly in the company’s founding documents (statuts) or later by a resolution passed at a general shareholders’ meeting. If an auditor has not been appointed or a vacancy arises due to resignation or dispute, the commercial court may designate one to ensure compliance with audit obligations. Compliance with the audit law in France requires companies to appoint both a principal (titular) auditor and an alternate auditor, who steps in if the primary auditor is unable to perform their duties. Auditors must be selected from the official registry maintained by the Haut Conseil du Commissariat aux Comptes (H3C). Rotation rules: Public Interest Entities (PIEs) are required to change their audit firms every 10 years. This rotation period can be extended up to 24 years if the audit firm is appointed through a competitive tender process, ensuring that companies periodically reassess and select their auditors transparently. For companies that are not classified as PIEs, auditors are typically appointed for a term of 6 years, but there is no strict requirement for mandatory rotation. You can read more about mandatory rotation of auditors in France here. Appointment

Audit Requirements in Australia vs France: Key Differences

Audit Requirements in Australia

Understanding the differences in audit requirements is essential for any multinational business seeking compliance, transparency, and investor confidence. In this blog we compare the auditing requirements in Australia and France. Regulatory Bodies and Audit Frameworks Both France and Australia have well-established regulatory systems that ensure the integrity and transparency of financial reporting. Auditing in France In France, the audit profession is regulated by the Haut Conseil du Commissariat aux Comptes (H3C), which ensures the quality and independence of auditors. Audits are performed in accordance with the Normes d’Exercice Professionnel (NEP), developed under the authority of the H3C. As France operates under a civil law system, audit obligations and professional standards are clearly defined and codified in legislation. Auditing in Australia In Australia, the Australian Securities and Investments Commission (ASIC) oversees the audit profession and enforces compliance with national auditing requirements. Auditors follow the Australian Auditing Standards (ASAs), which are based on the International Standards on Auditing (ISA). Unlike France, Australia applies a common law system, placing greater emphasis on principles, professional judgment, and sound corporate governance practices. Despite these differences, both frameworks aim to promote transparency, reliability, and trust in financial information. Auditing Process In both France and Australia, the purpose of auditing is the same: to verify the accuracy of financial statements, ensure transparency, and strengthen confidence in a company’s financial reporting. This means that auditors in both countries focus on confirming that the financial statements present a true and fair view of the company’s financial position in accordance with the respective national auditing standards. Throughout the audit process, they are also required to remain fully independent and objective to maintain the integrity of their opinion. Both jurisdictions also require auditors to report any irregularities they identify during their work, although the approach differs. In France, auditors have a formal procédure d’alerte (alert procedure), which obliges them to inform the company’s management and, if necessary, the commercial court when they detect irregularities that could threaten the company’s going concern. In contrast, Australia does not have a structured alert mechanism; however, auditors are legally required to report significant breaches or suspected misconduct to the Australian Securities and Investments Commission (ASIC). Additionally, French auditors play a broader role beyond the annual audit of financial statements. They may be appointed to perform specific assignments such as verifying the value of contributions during mergers, transformations, or capital increases. Statutory Auditing Requirement Thresholds Criteria France Australia Audit Requirement Trigger Mandatory if company exceeds 2 of 3 thresholds: • Balance sheet total: €5 million • Turnover (excl. VAT): €10 million • Employees: >50 Proprietary company considered “large” if it meets 2 of 3 thresholds: • Revenue: ≥ AUD 50 million • Gross assets: ≥ AUD 25 million • Employees: ≥100 Audit Obligation Large and medium-sized companies must appoint a statutory auditor (commissaire aux comptes). Large proprietary and all public companies must prepare audited financial reports. Small proprietary companies only if directed by ASIC or shareholders. Lower Thresholds for Subsidiaries Applies when controlled by an entity already audited: • Balance sheet: €2.5 million • Turnover: €5 million • Employees: >25 – Other Entities that need to conduct an Audit Non Profits are required if annual donations + subsidies exceed €153,000 or if recognized as public utility, issue bonds, or provide microloans. Companies limited by guarantee: • Revenue < AUD 1 million → audit or review • Revenue ≥ AUD 1 million → audit mandatory Public Companies All public limited companies (Société Anonyme – SA) require audits regardless of size. All public companies must prepare audited reports and lodge them with ASIC. Relief available for certain wholly owned subsidiaries (via ASIC Instrument 2016/785). Filing / Submission Timeline Financial statements filed annually with the Greffe du Tribunal de Commerce. Reports must be audited and lodged within 4 months after financial year-end (public companies). You can read more about audit requirements in France on our dedicated blog post. Auditor Appointment Appointment of an Auditor in France In France, a statutory auditor (commissaire aux comptes) can be appointed either directly in the company’s founding documents (statuts) or later by a resolution passed at a general shareholders’ meeting. If an auditor has not been appointed or a vacancy arises due to resignation or dispute, the commercial court may designate one to ensure compliance with audit obligations. Compliance with the audit law in France requires companies to appoint both a principal (titular) auditor and an alternate auditor, who steps in if the primary auditor is unable to perform their duties. Auditors must be selected from the official registry maintained by the Haut Conseil du Commissariat aux Comptes (H3C). Rotation rules: Public Interest Entities (PIEs) are required to change their audit firms every 10 years. This rotation period can be extended up to 24 years if the audit firm is appointed through a competitive tender process, ensuring that companies periodically reassess and select their auditors transparently. For companies that are not classified as PIEs, auditors are typically appointed for a term of 6 years, but there is no strict requirement for mandatory rotation. You can read more about mandatory rotation of auditors in France here. Appointment of an Auditor in Australia In Australia, an auditor may be an individual registered company auditor, a firm, or an authorised audit company. The directors of a public company must appoint an auditor within one month of registration, unless one has already been appointed at the general meeting. This appointment is then confirmed or replaced at the company’s first Annual General Meeting (AGM). For proprietary companies, the directors may appoint an auditor if one has not already been appointed by the members. Auditors remain in office until they resign with ASIC’s consent, are removed under Section 329, become ineligible, or the company is wound up. Moreover, a statutory auditor is extremely hard to get removed in Australia. The management needs to take permission of the central government after its board of directors recommends a proposal to this effect. However, this does not mean that auditors never

A Practical Guide to Audit Documentation for Companies in France

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When your company grows, restructures, or raises capital, several strategic operations may require the involvement of a statutory auditor (commissaire aux comptes). In France, these procedures are not just administrative formalities. They are essential steps to ensure transparency, protect shareholders, and build investor confidence. Yet, each type of audit or legal operation comes with its own set of required documents — often involving inputs from lawyers, chartered accountants, and management teams. This guide outlines the key documents you may need to prepare for the main types of audit engagements: statutory audits, contribution audits, transformation audits, merger audits, and equity operations. Statutory & Contractual Audit The statutory audit aims to ensures the accuracy and reliability of the annual financial statements. A contractual audit, on the other hand, is a voluntary engagement designed to strengthen investor confidence or prepare for a strategic transaction. Appointment: Statutory audit: appointed at the general assembly for six financial years. Contractual audit: freely chosen by the management or general assembly. Documents to be prepared* Sources Annual financial statements and appendices Chartered accountant Balance sheets, ledgers, journals Chartered accountant Intermediate financial statements Chartered accountant Minutes of general and board meetings Lawyer / Client Updated articles of association and shareholders agreement Lawyer Significant contracts Client Bank statements and confirmations Client / Chartered accountant Fixed asset register Chartered accountant Inventory, stock, and depreciation tests Client / Chartered accountant Tax declarations (corporate tax, VAT, etc.) Chartered accountant HR: DSN filings, registers, employment contracts Client Capitalization table and Shareholders’ register Lawyer / Client Legal disputes and lawyers’ attestations Lawyer Management representation letter Client *Non exhaustive list Contribution Audit The contribution auditor verifies the value of assets contributed (real estate, securities, business assets). This process helps protect shareholders and provides assurance to third parties regarding the fairness and accuracy of the valuation. Appointment: By unanimous agreement of the partners/shareholders, or failing that, by court order from the president of the commercial court. Documents to be prepared* Sources Draft articles of association including contributions Lawyer Valuation note / internal report Client / Chartered accountant Expert reports or third-party valuations Lawyer / Client Property deeds, notarized acts, Kbis extract Lawyer Financial statements (N-2 to N) Chartered accountant Capitalization table / Shareholders’ register Lawyer / Client Related contracts (leases, commercial agreements, etc.) Client Statement of debts linked to the asset Lawyer / Client Tax history (capital gains, depreciation) Chartered accountant Preparatory minutes of shareholders meetings Lawyer *Non exhaustive list Transformation Audit When a company changes its legal form (for example, from an SARL to an SAS) and does not have a statutory auditor (CAC) in place, an auditor must certify that the company’s equity is greater than or equal to its share capital. Appointment: By unanimous decision of the partners/shareholders, or failing that, by court order from the president of the commercial court. Documents to be prepared* Sources Draft articles of association post-transformation Lawyer Current articles of association and Kbis extract Lawyer Financial statement (less than 3 months old) Chartered accountant Statement of shareholders’ equity Chartered accountant Capitalization table / Shareholders’ register Lawyer / Client Draft minutes of transformation meeting Lawyer Statement of off-balance sheet commitments Lawyer / Client *Non exhaustive list Merger Audit During a merger, the auditor reviews the fairness of the share exchange ratio and ensures the protection of minority shareholders. Appointment: By court order from the president of the commercial court, unless all partners/shareholders of the companies involved unanimously agree to waive the requirement. Documents to be prepared* Sources Draft merger agreement Lawyer Draft amended articles of association Lawyer Management reports Lawyer / Client Annual financial statements (N-2 to N) Chartered accountant Interim financial statements Chartered accountant Valuations / due diligence reports Lawyer / Chartered accountant Minutes of corporate bodies Lawyer Statement of debts and off-balance sheet commitments Client Employee representative body (CSE) information/consultation Client Intragroup agreements Lawyer *Non exhaustive list Equity Operations In operations involving capital increases, fundraising, or the issuance of securities (BSPCE, BSA, OC, AGA, SO), the auditor ensures: the fairness of the valuation, the removal of pre-emptive subscription rights (DPS), and the protection of minority shareholders. Appointment: In-kind contributions / special benefits: by unanimous decision of the partners/shareholders, or by court order from the president of the commercial court (PTC) if unanimity is not reached. Removal of DPS / issuance of reserved securities: auditor appointed by court order from the PTC if no statutory auditor (CAC) is in place. Documents to be prepared* Sources Management report justifying the operation Lawyer / Client Draft amended articles of association Lawyer Pre-/post capitalization table Chartered accountant / Client Business plan, financial forecasts Chartered accountant / Client Term sheet / Shareholders’ agreement Lawyer In-kind contribution file Lawyer / Client Draft general assembly resolution Lawyer Annual financial statements (N, N-1, N-2) Chartered accountant Tax notes (share premium, BSPCE, etc.) Chartered accountant / Lawyer Issuance contracts (OC, BSPCE, etc.) Lawyer *Non exhaustive list Preparing the right documentation is one of the most effective ways to ensure that your audit or legal operation runs smoothly. Each type of audit, whether statutory, contribution-based, or linked to equity transactions, serves a different purpose, but they all share a common goal: securing your company’s growth with transparency and accuracy. At Reawave, our mission is to simplify these processes for you. By coordinating with your legal, accounting, and management teams, we turn complex compliance requirements into efficient, value-adding steps that build trust and strengthen your company’s financial credibility. Book a meeting today to get a personalized checklist for your next audit.

Why You Should Hire a Local Auditor in France as an International Company

Why Hire a Local Auditor in France

Expanding a business into France brings exciting opportunities, but it also introduces regulatory complexity. From navigating accounting standards in France to understanding unique France audit requirements, foreign companies often find themselves facing a steep learning curve. These challenges can be particularly overwhelming when attempting to comply with local laws while maintaining alignment with global policies. This is where the expertise of a local auditor in France becomes essential. A local firm doesn’t just ensure compliance, it acts as a strategic partner that understands the nuances of accounting in Europe, French business culture, and evolving regulatory demands. In this blog, we explore why working with a local auditor in France can help your business avoid costly errors and operate with confidence. Understanding France’s Audit and Accounting Environment Accounting Standards in France France has its own accounting and audit landscape, which differs significantly from many other countries. Companies operating in France are subject to Plan Comptable Général (PCG), France’s national accounting code, known as French GAAP. While IFRS may apply to consolidated accounts of listed companies, most businesses must still need to comply with local rules for statutory filings. You can learn more about the French GAAP here. Auditing Requirements in France When it comes to audits, France audit requirements depend on various factors such as company size, structure, and legal form. For example, SAS and SARL entities may be required to appoint a statutory auditor under certain circumstances. You can find an overview of auditing requirements in France here. Moreover, compared to general auditing in Europe, France maintains a stricter regulatory environment in some areas, including the mandatory appointment of auditors and detailed reporting expectations. This makes it all the more important to work with a firm that knows the ins and outs of accounting in Europe, and particularly French regulations. Benefits of Working With a Local Auditor in France as a Foreign Company Personalized Attention and Client Focus One of the biggest advantages of working with a local French audit firm is the personalized service you receive. Smaller, independent firms, like us, are more likely to take the time to understand your business in depth, its structure, goals, and pain points. This hands-on approach ensures tailored advice that aligns with your unique business needs. Deep Knowledge of Local Laws and Regulations Local firms bring invaluable expertise in France’s accounting standards, audit requirements, and business regulations. They stay closely informed of evolving tax laws, labor obligations, reporting rules, and sector-specific compliance. Their deep familiarity with auditing in France ensures that your business stays fully compliant with minimal risk of errors or penalties. This level of detail is hard to match without a strong local presence. Cost-Effective Without Compromising on Quality For small to mid-sized businesses, hiring a large international audit firm can be expensive. Local French audit firms often offer the same level of technical expertise and compliance assurance at a more accessible price point. Overall, with smaller firms, you benefit from professional, high-quality service without overextending your budget. Strong Community Ties and Market Insight Being embedded in the local business ecosystem gives these firms a unique edge. They understand the cultural, economic, and operational nuances of working in France and are often well-connected to local networks, authorities, and institutions. This can help you better navigate the market, form the right partnerships, and avoid pitfalls. Their on-the-ground experience allows for more practical, relevant advice that supports sustainable growth. The Limitations of Relying Solely on International Networks Many multinational businesses work with large global firms or internal finance teams to manage operations across markets. While these resources are useful, relying solely on international auditors can be risky in France. What is an international auditor? Typically, an international auditor is a large network-based firm that provides services in multiple jurisdictions. While these firms offer global reach, they may lack deep, hands-on knowledge of the France audit requirements and accounting standards in France, especially at the local level. Issues like tax audit triggers, social security filings, and sector-specific reporting are often best handled by a French audit firm that is embedded in the local system. A local French accounting firm complements your international setup by ensuring your French entity is fully compliant and well-represented in front of local authorities. Expanding into France is a smart move, but working with a local French audit and accounting firm makes it even smarter. From tailored advice and cost-effective services to deep regulatory knowledge and cultural insight, local firms offer strategic value that international networks often can’t match. If you want reliable, personalized support for your business in France, partnering with a local expert is the way forward. Explore our auditing services.  

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