United Kingdom Tax Matters. (a) The provisions of this Section 5.12 shall only apply in respect of any UK Borrower or any other Borrower to the extent only that it makes a payment of interest that is treated as having a UK source for UK tax purposes (a “Relevant Borrower”), and in respect of any such UK Borrower the provisions of Sections 5.9, 5.10 and 5.11 shall not apply.
United Kingdom Tax Matters. (a) The provisions of this Section 3.08 shall only apply in respect of any UK Borrower, and in respect of any such UK Borrower, the provisions of Section 3.01 shall not apply.
United Kingdom Tax Matters. The provisions of Section 5.8 (other than this Section 5.8.4)
United Kingdom Tax Matters. (a) This Option is a nonqualified option under the United States’ Internal Revenue Code of 1986, as amended. The Company does not make any representation regarding whether the Option is tax-qualified under the tax laws of England or the United Kingdom and provides no assurances as to the tax consequences of this Option under the tax laws of England or the United Kingdom.
United Kingdom Tax Matters. 10.1 For the purposes of United Kingdom corporation tax, any Adjusted Global Net Income shall be allocated to the Members in accordance with Clause 7 and any Adjusted Global Net Losses shall be allocated in accordance with Clause 8.
United Kingdom Tax Matters. The provisions of Section 5.8 (other than this Section 5.8.9) shall not apply, and instead the provisions this Section 5.8.9 shall apply, to any advance under any Loan Document to any UK Borrower or any other Borrower to whom the provisions of Section 874 ITA would apply (ignoring any exceptions) on the payment of any amount of interest (each a “Relevant Borrower” for the purposes of this Section 5.8.9) to any Lender.
United Kingdom Tax Matters. (c) The provisions of this Section 5.12 shall only apply in respect of any UK Borrower (a “Relevant Borrower”), and in respect of any such UK Borrower the provisions of Sections 5.9, 5.10 and 5.11 shall not apply.
United Kingdom Tax Matters. Instead of Sections 5.8.1, 5.8.2, 5.8.3 and 5.8.5, the provisions of this Section 5.8.8 shall apply to any advance under any Loan Document to any UK Borrower (each a “Relevant Borrower” for the purposes of this Section 5.8.8): Solely for the purposes of this Section 5.8.8, the following terms shall have the following meanings:
United Kingdom Tax Matters. The provisions of this Section 3.01(b) shall apply only in relation to any Loan which is at any time outstanding between any Lender and the U.K. Foreign Borrower.
United Kingdom Tax Matters. (a) The provisions of this Section 2.22 shall only apply in respect of any European Borrower or any other Borrower to whom the provisions of Section 874 ITA would apply (ignoring any exceptions) on the payment of any amount of interest (a "Relevant Borrower") to any Lender.
