Tax Efficiency. The General Partner will use reasonable efforts to ensure that the Partnership holds investments in the most tax efficient way reasonably practicable taking into account and balancing the relative interests of the Partners and will use reasonable efforts to meet the conditions of and to benefit from participation exemption regimes, the EU-Parent Subsidiary Directive, the EU-Interest and Royalties directive and other relevant treaties where applicable and cause Portfolio Companies and Partnership Investment Vehicles to maintain sufficient substance and hold such investments as to gain such benefits.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Host Hotels & Resorts, Inc.), Limited Partnership Agreement (Host Hotels & Resorts, Inc.)
Tax Efficiency. The General Partner will use reasonable efforts to ensure that the Partnership holds investments in the most tax efficient way reasonably practicable taking into account and balancing the relative interests of the Partners and will use reasonable efforts to meet the conditions of and to benefit from participation exemption regimes, the EU-Parent Subsidiary Directive, the EU-Interest and Royalties directive and other relevant treaties where applicable and cause Portfolio Companies and Partnership Investment #10338536v8 Vehicles to maintain sufficient substance and hold such investments as to gain such benefits.
Appears in 1 contract
Sources: Limited Partnership Agreement (Host Hotels & Resorts L.P.)