Indirect Transfers definition

Indirect Transfers has the meaning set forth in Section 6.5(g)(iii)(B).
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Indirect Transfers is defined in Section 11.1(e) .
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Examples of Indirect Transfers in a sentence

  • In this context: - Direct Transfers of Values are provided to the recipient by our Company directly,- Indirect Transfers of Values are provided to the recipient through a third party.

  • For example, Liberia decided not to include a step-up provision in its Indirect Transfer tax law (see Box 9).The third alternative is simply to reduce the level of tax on Indirect Transfers, thus reducing the effect of the two levels of tax, while also denying the buyer any step-up in basis of the source country company’s assets.

  • This discussion supplements the discussion in Section A of the paper concerning the Platform’s two alternative models for taxing Indirect Transfers.

  • DESIGNING A LAW WITH IMPLEMENTATION AND ENFORCEMENT IN MIND Enforcing a capital gains tax on Indirect Transfers is fraught with challenges: first, such transactions are hard to detect because they occur offshore and, second, even if detected, it is hard to penalize a non-resident seller for defaulting on a tax payment due to the source country.

  • The provision used by China is specifically directed at Indirect Transfers and so is a version of a SAAR.• GAAR: A country could adopt a GAAR that that would cover any transaction not having a bona fide commercial purpose, including Indirect Transfers.

  • INTRODUCTION 1.1 Types of Indirect Transfers - the Headlines A brief examination of several cases will serve to illustrate the nature of the issues raised by Indirect Transfers.

  • Finally, a step-up should only be adopted for Indirect Transfers if a jurisdiction also provides for it in purely domestic transactions.

  • The Platform Paper goes into an extended discussion of the economics underlying the source country’s right to tax Indirect Transfers, including a discussion of “location specific rents”.

  • Historically, the reach of a country’s law extended only to persons or property within the jurisdiction of the courts of the country.10 This notion underlies the historical focus of the tax law on taxing Indirect Transfers only of “immovable property,” which is the type of property that clearly lies within a given jurisdiction (since literally it cannot be moved).

  • Building on the momentum created by the Platform’s paper on taxing Indirect Transfers of source country assets, this paper aims at providing practical guidance to address the taxation of Indirect Transfers of assets of extractive industries that are located in developing countries.

Related to Indirect Transfers

  • Permitted Transfers has the meaning set forth in Section 4.2.17(d).

  • Subject Transaction as defined in Section 6.8(d).

  • Disqualified Transferee means any Person who is a direct or indirect transferee of any Right from an Acquiring Person or an Affiliate of an Acquiring Person and became such a transferee (x) after the occurrence of a Common Stock Event or (y) prior to or concurrently with the Acquiring Person becoming such and received such Right pursuant to a transfer (whether or not for value) (A) from the Acquiring Person to holders of its Common Stock or other equity securities or to any Person with whom the Acquiring Person has any continuing agreement, arrangement, or understanding (whether or not in writing) regarding the transferred Right, or (B) which a majority of the Board reasonably determines is part of a plan, arrangement, or understanding (whether or not in writing) which has as a primary purpose or effect, the avoidance of Section 7(e) hereof.

  • Indirect Ownership Interest means an ownership interest in an entity that has an ownership interest in another entity. Indirect ownership interest includes an ownership interest in an entity that has an indirect ownership interest in another entity.

  • Permitted Transfer has the meaning set forth in Section 10.02.

  • Exempt Transfer means, in relation to shares held by a member:

  • Permitted Asset Sale means any Asset Sale that is permitted under Section 6.8.

  • Asset Transfer means a sale, lease, exclusive license or other disposition of all or substantially all of the assets of the Company.

  • Permitted Transactions has the meaning set forth in Section 13(B).

  • Qualified Transferee means an “accredited investor” as defined in Rule 501 promulgated under the Securities Act.

  • Applicable Ownership Interest means, with respect to the Treasury portfolio,

  • Designated Payment/Transfer Office means (i) with respect to the initial Paying Agent/Registrar named herein, its office in Dallas, Texas, or at such other location designated by the Paying Agent/Registrar and (ii) with respect to any successor Paying Agent/Registrar, the office of such successor designated and located as may be agreed upon by the City and such successor.

  • Beneficial Ownership Interest means the right to receive payments and notices with respect to the Bonds held in a Book Entry System.

  • Transfers and “Transferred” have the correlative meanings.

  • Permitted Business Investments means Investments made in the ordinary course of, and of a nature that is or shall have become customary in, the Oil and Gas Business, including through agreements, transactions, interests or arrangements that permit one to share risk or costs, comply with regulatory requirements regarding local ownership or satisfy other objectives customarily achieved through the conduct of the Oil and Gas Business jointly with third parties, including without limitation:

  • Dispositions has the meaning provided in Section 6.02.

  • Control Investment Affiliate as to any Person, any other Person that (a) directly or indirectly, is in control of, is controlled by, or is under common control with, such Person and (b) is organized by such Person primarily for the purpose of making equity or debt investments in one or more companies. For purposes of this definition, “control” of a Person means the power, directly or indirectly, to direct or cause the direction of the management and policies of such Person whether by contract or otherwise.

  • Non-Transfer Event means any event or other changes in circumstances other than a purported Transfer, including, without limitation, any change in the value of any Shares.

  • Permitted Asset Swap means the substantially concurrent purchase and sale or exchange of Related Business Assets or a combination of Related Business Assets and Cash Equivalents between the Issuer or any of its Restricted Subsidiaries and another Person; provided that any Cash Equivalents received must be applied in accordance with Section 4.10 hereof.

  • Modified Eligible Transferee means any bank, financial institution or other entity which is regularly engaged in or established for the purpose of making, purchasing or investing in loans, securities and other financial assets.

  • Exempt Transactions means the transactions described in the section hereof titled “Exempt Transactions.”

  • Restricted Investments means all Investments except the following:

  • Wholly Owned Domestic Subsidiary means a Wholly Owned Subsidiary that is also a Domestic Subsidiary.

  • Disqualified Equity Interest means, with respect to any Person, any Equity Interest in such Person that by its terms (or by the terms of any security into which it is convertible or for which it is exchangeable, either mandatorily or at the option of the holder thereof), or upon the happening of any event or condition:

  • Excluded Transfer means any transfer of VMTP Shares (1) to a tender option bond trust in which the Purchaser and/or its Affiliates collectively own all of the residual interests, (2) in connection with a distribution in-kind to the holders of securities of or receipts representing an ownership interest in any tender option bond trust in which the Purchaser and/or its Affiliates collectively own all of the residual interests, (3) in connection with a repurchase financing transaction or (4) relating to a collateral pledge arrangement.

  • Permitted Transaction means any transaction involving (i) a Swap that is not a Required Transaction or (ii) a Required Transaction that is a component of a Covered Package Transaction.