UK Tax. (a) Unless a contrary indication appears, in this Section 2.17A a reference to “determines” or “determined” means a determination made in the absolute discretion of the person making the determination.
UK Tax. (a) Each Loan Party shall make all payments to be made by it under a Loan Document without any Tax Deduction, unless a Tax Deduction is required by law.
UK Tax. For the avoidance of doubt, nothing in this Section 2.17 shall apply in relation to UK Tax, to which the provisions of Section 2.18 shall apply.
UK Tax. (a) Definitions:
UK Tax. Part 3 of Annex A-1 (“Representations and Warranties of the Buyer in relation to UK Tax Matters”) shall apply in respect of the UK Business and shall have effect as if set out in this Section 4.6.
UK Tax. 1 [(A) The Assignee confirms that it is: (a) [a UK Qualifying Lender (other than a UK Treaty Lender);] (b) [a UK Treaty Lender;] (c) [not a UK Qualifying Lender.]]2 [(B) The Assignee confirms that the person beneficially entitled to interest payable to such Assignee in respect of an advance under a Loan Document is either: (a) a company resident in the United Kingdom for United Kingdom tax purposes; (b) a partnership each member of which is (i) a company so resident in the United Kingdom, (ii) a company not so resident in the United Kingdom which carries on a trade in the United Kingdom through a permanent establishment and which brings into account in computing its chargeable profits (within the meaning of section 19 of the UK CTA) the whole of any share of interest payable in respect of that advance that falls to it by reason of Part 17 of the UK CTA, or (c) a company not so resident in the United Kingdom which carries on a trade in the United Kingdom through a permanent establishment and which brings into account interest payable in respect of that advance in computing the chargeable profits (within the meaning of section 19 of the UK CTA) of that company.]3 [(C) The Assignee confirms that it holds a passport under the HM Revenue & Customs DT Treaty Passport scheme (reference number [ ]) and is tax resident in [ ].]4 2.
UK Tax. 1) We do not apply VAT to the rental fee charged to the Guest. Our commission is applied to the achieved rental and it is up to you to deal with any VAT contributions due to HMRC if you are VAT registered.
UK Tax. 9.1 The UK Seller shall indemnify each Purchaser and the Company in respect of any amount payable by any of them in respect of a Tax liability of the Company (other than any liability to stamp duty or stamp duty land tax and for the avoidance of doubt the Purchasers shall be responsible for any stamp duty land tax cost arising as a result of the Hive Down) arising as a result of the Company ceasing to be a member of the same group as the UK Seller for UK Tax purposes as a result of the sale of the Shares pursuant to this Agreement (excluding for the avoidance of doubt an amount equal to any such Tax Liability which is taken into account or otherwise provided for in the Completion Working Capital Statement). The UK Seller may, but shall not be obliged to, subject to Clause 9.2 below, determine that any available election for such liability to be transferred to it or to another member of its group should be made and, if the UK Seller so determines, SPI shall take or shall procure that the Company takes any steps reasonably requested by the UK Seller, including joining in any relevant election, in connection with the transfer of such liability. No liability shall arise for the UK Seller under this Clause 9.1 to the extent that the relevant liability is sheltered by the use of pre-Completion reliefs (which include, for the avoidance of doubt, reliefs transferred to the Company as a result of the Hive Down, to the extent that the Company is able to make use of such reliefs, having used reasonable endeavours to do so) such reliefs to be deemed for the purposes of this Clause to be used in priority to any other reliefs available to the Company to shelter such tax to reduce or eliminate such Tax liability.
UK Tax. [(A) The Assignee confirms that it is:
UK Tax. 17 17 If the Assignee is lending to a UK Borrower, include relevant statements as set out below. [(A) The Assignee confirms that it is:
