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The heavier seasoned it is, the warmer it should be as well.
There's a quite infamous stout here which I don't even put in the fridge at all. Just store it at room temperature.
And it's only 8%
The darker it is, the warmer it should be.
The more seasoning is used, the warmer it should be.
Plain lagers and Weißbeer are best served cooler.
This is just my experience however.