Conforming Tax Rulings definition

Conforming Tax Rulings means Tax Rulings where both confirm the same tax treatment of the sale of the [ownership] [perpetual usufruct] of the Land an the ownership of the Building by the Seller to the Purchaser. It means that both either state that: (i) the sale of the perpetual usufruct of the Land and the ownership of the Building by the Seller is subject to VAT and is not VAT exempt or (ii) the sale of the perpetual usufruct of the Land and the ownership of the Building by the Seller to the Purchaser is exempt from VAT and as a result (a) the Purchaser would be disallowed recovery of input VAT resulting from such transaction and (b) the sale is subject to a tax on civil transaction;
Sample 1

Related to Conforming Tax Rulings

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • Pre-Closing Tax Return means any Tax Return that is required to be filed for any Acquired Companies, the Seller or any of its Affiliates with respect to a Pre-Closing Tax Period.

  • Pre-Closing Tax Returns is defined in Section 6.7(b)(iii).

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

  • Pre-Closing Tax Period means any Tax period ending on or before the Closing Date.

  • Post-Closing Tax Period means any Tax period (or portion thereof) beginning after the Closing Date.

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • Tax Ordinance means the Israeli Income Tax Ordinance [New Version], 1961, as amended.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended.

  • Pre-Closing Tax Periods means any and all Tax periods that end on or before the Closing Date and the portion of any Straddle Period ending at the end of day on which the Closing occurs.

  • Post-Closing Taxes means Taxes of the Company for any Post-Closing Tax Period.

  • Pre-Closing Taxes means Taxes of the Company for any Pre-Closing Tax Period.

  • Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • Issuer Tax Opinion means with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes and subject to customary assumptions and qualifications for opinions of this type, (a) such action will not adversely affect the tax characterization as debt of any Notes that were characterized as debt at the time of their issuance, and (b) following such action neither the Issuer nor the Titling Trust will be treated as an association (or publicly traded partnership) taxable as a corporation.

  • Australian Tax Act means the Income Tax Assessment Act 1936 (Cth) (Australia) or the Income Tax Assessment Act 1997 (Cth) (Australia), as applicable.

  • Excise Tax Act means the Excise Tax Act (Canada);

  • Swiss Withholding Tax Act means the Swiss Federal Act on the Withholding Tax of 13 October 1965 (Bundesgesetz über die Verrechnungssteuer), together with the related ordinances, regulations and guidelines, all as amended and applicable from time to time.

  • Non-U.S. Tax Person A person other than a U.S. Tax Person.

  • Private Letter Ruling shall have the meaning set forth in the Recitals.

  • High Quality Short-Term Debt Instruments means any instrument that has a maturity at issuance of less that 366 days and that is rated in one of the two highest rating categories by a Nationally Recognized Statistical Rating Organization.

  • U.S. Tax Certificate has the meaning assigned to such term in Section 2.17(f)(ii)(D)(2).

  • Tax Representation Letters means the representations provided by Kontoor Brands and VF to Tax Advisers in connection with the rendering by Tax Advisers of the Tax Opinions.