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None of the PSRs for Coding Standards, nor PER-CS, explicitly indicate whether the opening tag for PHP should be in lowercase, though this is very much implied in PSR-1 - see https://www.php-fig.org/psr/psr-1/#1-overview
It probably should be explicitly stated in the next version of PER-CS.
Also, it should be noted that php-cs-fixer does force the opening tag to be in lowercase, whilst phpcs does not.
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enhancementNew feature or requestNew feature or request