Anti-Avoidance Provisions. Neither of the Group Companies has since its incorporation engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or could be said to be the avoidance of, or deferral of or a reduction in the liability to, Tax.
Anti-Avoidance Provisions. The Company has neither been a party to nor otherwise involved in any transaction, scheme or arrangement which reduces or would reduce the amount of Tax payable by any person and which is artificial or fictitious or in respect of which any disposition is not given effect to within the meaning of the applicable Tax Legislation.
Anti-Avoidance Provisions. The Company has not since its incorporation engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or could be said to be the avoidance of, or deferral of or a reduction in the liability to, Taxation.
Anti-Avoidance Provisions. 19.1 No Target Group Company has in the seven years ending on the date of this Agreement been engaged in, or been a party to or otherwise involved in, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or could be said to be the avoidance of Taxation or deferral of or a reduction in the liability to Taxation or account for any Taxation.
Anti-Avoidance Provisions. The Income Tax Act contains a general anti-avoidance rule that targets “impermissible avoidance arrangements”. The enquiry focuses on a consideration of whether the transaction: • was entered into for the sole or main purpose of obtaining a tax benefit; • was entered into or carried out in a manner not normally employed for bona fide business purposes, other than the obtaining of a tax benefit; • lacks commercial substance, in that it results in a significant tax benefit for a party, but does not have a significant effect on either the business risks or net cash flows of that party taking into account indicators such as the presence of round-trip financing, accommodating or tax-indifferent parties and offsetting elements; • has created rights or obligations that would not normally be created between persons dealing at arm’s length; or • would result directly or indirectly in the misuse or abuse of the provisions of the Income Tax Act. If the anti-avoidance provisions apply, SARS is entitled to determine the tax liability of the relevant party either as if the transaction had not been entered into “or in such manner as in the circumstances of the case he deems appropriate”. There are a number of other anti-avoidance provisions in various sections of the Income Tax Act, dealing with particular transactions. The Income Tax Act contains a provision that is specifically aimed at arrangements that have been entered into or affected by any person solely or mainly for the purpose of using any assessed loss, any balance of assessed loss, any capital loss or any assessed capital loss incurred by a company or trust, in order to avoid liability (on the part of that company or trust or any other person) for the payment of any tax, duty or levy on income, or to reduce the amount thereof. SARS may, if it is satisfied that the provision applies, disallow the offset of any such losses against income or capital gains, as appropriate. In addition to the general anti-avoidance arrangements, the South African courts may also seek to apply the substance- over-form doctrine and impose tax on the true intention of a transaction if that differs from the actual agreements. CHAPTER Transfer pricing South African transfer pricing rules apply in relation to any transaction, operation, scheme, agreement or understanding which is entered into directly or indirectly, or affected between or for the benefit of either or both: • a person that is a resident; and - any other person that is no...
Anti-Avoidance Provisions. ADI has neither been a party to nor otherwise involved in any transaction, scheme or arrangement the main purpose or object or one of the main purposes or objects of which was to avoid or reduce a liability to tax.
Anti-Avoidance Provisions. None of the Group Companies has during the period commencing on 15 May 2002 and ending on the date of this Agreement engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or determined to be the avoidance of, or deferral of or a reduction in the liability to, Tax.
Anti-Avoidance Provisions. The Company has not since its incorporation engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or could be said to be, the avoidance of, or deferral of or a reduction in the liability to, Taxation. This Agreement has been entered into on the date stated at the beginning. THE SELLERS SIGNED by DXXXX XXX XXXXXX /s/ Dxxxx Xxx Xxxxxx SIGNED by MU POH AUN /s/ Mu Poh Aun SIGNED by NG POOK SING /s/ Ng Pook Sing SIGNED by CXXXX KAR CXXX /s/ Cxxxx Kar Cxxx THE PURCHASER SIGNED by for and on behalf of STARBOX INTERNATIONAL LTD. (Registration No. 2120999) /s/ Cxxx Xxxx Xxx Name: Cxxx Xxxx Xxx Designation: Director THE ISSUER SIGNED by for and on behalf of STARBOX GROUP HOLDINGS LTD. (Registration No. 381005) /s/ Lxx Xxxxx Xxxx Name: Lxx Xxxxx Xxxx Designation: Chief Executive Officer
Anti-Avoidance Provisions. None of the Group Companies has knowingly since its incorporation engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was to be the avoidance of its respective liability to, Taxation.
Anti-Avoidance Provisions. 5.5.1 The Company has not engaged in, or been a party to, any transaction or series of transactions or scheme or arrangement of which the main purpose, or one of the main purposes, was or could be said to be the avoidance of, or deferral of or a reduction in the liability to, taxation.
