Group Relief. 7.1 Except as provided in the Accounts, neither the Company nor any Subsidiary is or will be obliged to make or be entitled to receive any payment for group relief as defined in section 402(6) of ICTA 1988 in respect of any period ending on or before the Accounts Date, or any payment for the surrender of the benefit of an amount of advance corporation tax or any repayment of such a payment.
Group Relief. Except as provided in the Accounts, the Company is not, nor will be, obliged to make or be entitled to receive any payment for the surrender of group relief as defined in section 183 of CTA 2010 in respect of any period ending on or before the Completion Date, or any payment for the surrender of the benefit of an amount of advance corporation tax or any repayment of such a payment.
Group Relief. The Disclosure Letter contains particulars of all arrangements relating to group relief under sections 402-413 of ICTA to which the Company is or has been a party and:-
Group Relief. (a) The Disclosure Letter sets out full and accurate details of every agreement that any Group Company has within the last seven years entered into for the claim or surrender of any group relief under the provisions of Part 5 (Group relief) of the CTA 2010 (formerly section 402-413 (inclusive) of the ICTA 1988), of advance corporation tax under the provisions of section 240 of, or Schedule 13A to, the ICTA 1988 or of a tax refund under section 963 of the CTA 2010 (formerly section 102 of the Finance Act 1989).
Group Relief. (i) In the case of Tax Returns described in clause (ii) of the definition of "Combined Return," where current period or brought forward losses or excess charges of one entity can be surrendered to or utilised by another entity, representatives of SCL and XXXX shall agree before any tax filings are made, what losses or charges are to be surrendered between entities and shall prepare the necessary elections or filings for this surrender, utilisation or loss claim. To facilitate this agreement, the representatives of each group shall advise the other group representative the extent of the losses or charges that are potentially available for surrender to the other group or the extent of the losses or charges that the group wishes to claim from the other group. In all cases, howsoever the parties subsequently may amend their tax returns or computations, when the parties initially advise each other of the quantity of losses or excess charges that could be surrendered or the losses or charges which could be claimed, each entity within each group will include in its computation of taxable income or loss all available allowances, deductions or charges that it is legally allowed to make. If the representatives of SCL and XXXX are unable to agree what losses or charges shall be surrendered between entities, either party wishing to claim the losses or charges from another entity must put the request in writing. The group receiving this request must respond to it within 5 days of the request being made, unless this deadline is extended by the agreement of both of the groups.
Group Relief. Where and to the extent that the Sellers would otherwise be liable to indemnify against or otherwise discharge Taxes of a Purchased Entity under this Agreement or the Sellers have agreed on or before the Closing Date to surrender a specific amount of losses (even if such amount is provisional) under a pre-existing contractual arrangement, the Sellers shall and shall procure that their Affiliates shall cooperate fully in surrendering to the Purchased Entities all group relief and consortium relief amounts, up to the amount for which the Sellers would otherwise be liable or which has been agreed to be surrendered, that such Purchased Entities are entitled to claim in accordance with the ICTA.
Group Relief. For any accounting period ending prior to the Deconsolidation Year and beginning on or after the Effective Date:
Group Relief. For any accounting period beginning after the accounting periods described in Section 3.14 hereof:
Group Relief. The Disclosure Letter details all relevant surrenders of or claims for group relief or advance corporation tax which affect any of the Companies for accounting periods in respect of which no final agreement has been reached with the relevant Tax Authority as to its Tax affairs or which were made in the seven years ending with the date of this Agreement.
Group Relief. (a) (i) SpinCo shall procure that each relevant member of the SpinCo Group shall surrender to, or claim from, a relevant member of the Distributing Group, and (ii) Distributing shall procure that each relevant member of the Distributing Group shall claim from, or surrender to, a relevant member of the SpinCo Group, any Group Relief available in respect of all Pre-Distribution Periods, provided that neither SpinCo nor Distributing shall be obliged to procure that any member of its Group makes (x) any such surrender of Group Relief to a member of the other Group ahead of any surrender of Group Relief to another member of its own Group, or (y) any such claim of Group Relief from a member of the other Group ahead of any claim of Group Relief available from a member of its own Group. Distributing and SpinCo shall procure that the relevant members of its Group use all reasonable endeavors to procure that full effect is given to surrenders and claims to be made under this Section 3.9 and that such surrenders and claims are allowed in full by HM Revenue & Customs, including signing and submitting to HM Revenue & Customs all such notices of consent to surrender (including provisional or protective notices of consent in cases where any relevant UK corporation tax computation has not yet been agreed).
