Irish Treaty Lender definition

Irish Treaty Lender means a Lender which is treated as a resident of an Irish Treaty State for the purposes of the Treaty, does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Loan is effectively connected and meets all other conditions in the relevant Treaty for full exemption from tax imposed by Ireland on interest (assuming the completion of any necessary procedural formalities).
Irish Treaty Lender means, in respect of an Irish Borrower, a Lender which:
Irish Treaty Lender means a Lender which: (a) is treated (subject to the completion of procedural formalities) as a resident of an Irish Treaty State for the purposes of the relevant Irish Tax Treaty, and (b) does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Advance is effectively connected, and (c) fulfills all other conditions which must be fulfilled under the Irish Tax Treaty by residents of that Irish Treaty State for such residents to obtain full exemption from taxation on interest imposed by Ireland, subject to the completion of procedural formalities.

Examples of Irish Treaty Lender in a sentence

  • The Company is not required to make any deduction on account of Irish tax from any payment it may make under any Loan Document to a Lender which is an Irish Qualifying Lender subject, in the case of an Irish Treaty Lender, to the completion of any necessary procedural formalities.

  • Company which makes a payment to which that Irish Treaty Lender is entitled shall co-operate in completing any procedural formalities necessary for the Company to obtain authorisation to make that payment without a Tax Deduction.

  • If a New Lender fails to indicate its status in accordance with this Section 2.17(j) then such New Lender shall be treated for the purposes of this Agreement (including by each Borrower or Guarantor) as if it is not an Irish Qualifying Lender or Irish Treaty Lender (as applicable) until such time as it notifies the Administrative Agent which category applies.

  • If a New Lender fails to indicate its status in accordance with this Section 2.14(j) then such New Lender shall be treated for the purposes of this Agreement (including by each Borrower or Guarantor) as if it is not an Irish Qualifying Lender or Irish Treaty Lender (as applicable) until such time as it notifies the Administrative Agent which category applies.

  • An Irish Treaty Lender and the Borrower shall co-operate in completing any procedural formalities necessary for it to obtain authorisation to make that payment without a Tax Deduction on account of Tax imposed by Ireland.


More Definitions of Irish Treaty Lender

Irish Treaty Lender means a Lender Party (other than a Lender falling within paragraph (b), (c), (d) or (e) of the definition ofIrish Qualifying Lender”) which is on the date any relevant payment is made, is entitled (subject to provision of the relevant self-certificate form) under a Treaty in force on that date to that payment without any Irish Tax Deduction.
Irish Treaty Lender means a Lender which is on the date the relevant payment is made entitled under a double taxation agreement (an “Irish Treaty”) in force on that date between Ireland and another jurisdiction to that payment without any withholding for or on account of Irish Tax (subject to the completion of any procedural formalities) and which does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Loan is effectively connected.
Irish Treaty Lender means a Lender, other than a Lender falling within paragraph (b) of the definition ofIrish Qualifying Lender” which, subject to the completion of all necessary procedural formalities:
Irish Treaty Lender means a Lender, which on the date any relevant payment is made:
Irish Treaty Lender a Person who:
Irish Treaty Lender means a Finance Party which:
Irish Treaty Lender means, a Lender, other than a Lender falling within clause (b) of the definition of Irish Qualifying Lender, which (a) is treated as a resident of an Irish Treaty State for the purposes of an Irish Tax Treaty, (b) does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in this Agreement is effectively connected and (c) (subject to the completion of any procedural formalities) fulfils any other conditions which must be fulfilled under an Irish Tax Treaty by residents of that Irish Treaty State for such residents to obtain full exemption from tax imposed by Ireland on interest payable under a Loan Document.