BEPS Clause Samples

BEPS. (a) To the extent that the Company incurs any Tax that makes the effective Tax rate of the Company and its Subsidiaries (if any) and branches in Ireland (assessed on a standalone basis) for any applicable period exceed 15% under any Applicable Law in Ireland based on the GloBE Rules solely as a result of the Company and/or any Subsidiary or branch being a Constituent Entity of an MNE Group of which Intel Member or any of its Affiliates (other than the Company or any of its Subsidiaries) is the Ultimate Parent Entity (a “Pillar 2 Tax”), then Intel Member shall (A) promptly notify Co-Investor Member upon becoming aware of such Pillar 2 Tax and (B) pay the Company and its Subsidiaries the amount required to ensure that Co-Investor Member shall receive the same amount as it would have received on an “after-tax basis” under this Agreement had no such Pillar 2 Tax been incurred. For the avoidance of doubt, any such payment made by Intel Member pursuant to this Section 13.15(a) shall constitute an Additional Intel Contribution. (b) For the purposes of this Section 13.15, the terms “Constituent Entity”, “MNE Group” and “Ultimate Parent Entity” shall be construed in accordance with the OECD “Pillar Two” rules relating to global minimum tax / the Global Anti-Base Erosion Rules (the “GloBE Rules”) and/or in accordance with any equivalent or similar terms in any legislation based on the GloBE Rules that is adopted in Ireland.
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BEPS why you’re taxed more than a multinational, OECD Insights (Feb. 13, 2013), ▇▇▇▇://▇▇▇▇▇▇▇▇▇▇▇▇.▇▇▇/2013/02/13/beps-why-youre-taxed-more-than-a-multinational.
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Related to BEPS

  • STATEWIDE ACHIEVEMENT TESTING When CONTRACTOR is a NPS, per implementation of Senate Bill 484, CONTRACTOR shall administer all Statewide assessments within the California Assessment of Student Performance and Progress (“CAASPP”), Desired Results Developmental Profile (“DRDP”), California Alternative Assessment (“CAA”), achievement and abilities tests (using LEA-authorized assessment instruments), the Fitness Gram, , the English Language Proficiency Assessments for California (“ELPAC”), and as appropriate to the student, and mandated by LEA pursuant to LEA and state and federal guidelines. CONTRACTOR is subject to the alternative accountability system developed pursuant to Education Code section 52052, in the same manner as public schools. Each LEA student placed with CONTRACTOR by the LEA shall be tested by qualified staff of CONTRACTOR in accordance with that accountability program. ▇▇▇ shall provide test administration training to CONTRACTOR’S qualified staff. CONTRACTOR shall attend LEA test training and comply with completion of all coding requirements as required by ▇▇▇.

  • Performance Expectations The Charter School’s performance in relation to the indicators, measures, metrics and targets set forth in the CPF shall provide the basis upon which the SCSC will decide whether to renew the Charter School’s Charter Contract at the end of the charter term. This section shall not preclude the SCSC from considering other relevant factors in making renewal decisions.

  • Goals & Objectives The purpose of this Agreement is to ensure that the proper elements and commitments are in place to provide consistent IT service support and delivery to the Customer by the Service Provider. The goal of this Agreement is to obtain mutual agreement for IT service provision between the Service Provider(s) and Customer(s). The objectives of this Agreement are to: • Provide clear reference to service ownership, accountability, roles and/or responsibilities. • Present a clear, concise and measurable description of service provision to the customer. • Match perceptions of expected service provision with actual service support & delivery.

  • Multi-year Planning Targets Schedule A may reflect an allocation for the first Funding Year of this Agreement as well as planning targets for up to two additional years, consistent with the term of this Agreement. In such an event, the HSP acknowledges that if it is provided with planning targets, these targets: a. are targets only, b. are provided solely for the purposes of planning, c. are subject to confirmation, and d. may be changed at the discretion of the Funder in consultation with the HSP. The HSP will proactively manage the risks associated with multi-year planning and the potential changes to the planning targets; and the Funder agrees that it will communicate any changes to the planning targets as soon as reasonably possible.

  • Excellence excellence is the result of always striving to do better. This is represented by constant improvements to the way in which we deliver our services, which results in a high performing health service. • Respect – we demonstrate respect through our actions and behaviours. By showing each other respect, in turn we earn respect. • Integrity – integrity is doing the right thing, knowing it is what we do when people aren’t looking that is a true reflection of who we are. • Collaboration – collaboration represents working together in partnership to achieve sustainable health care outcomes for our community with a shared understanding of our priorities. • Accountability – together we have a shared responsibility for ensuring the best health care outcomes for our community. This is a reminder that it is not only our actions, but also the actions we do not do, for which we are accountable.