Spanish Treaty Lender in respect of a Spanish Borrower, a Lender which (a) is treated as a resident of a Spanish Treaty State for the purposes of such Spanish Treaty; (b) does not carry on a business in Spain through a permanent establishment with which that Lender’s participation in the Loan is effectively connected; and (c) fulfils any other procedural conditions which must be fulfilled under the Spanish Treaty by residents of that Spanish Treaty State for such residents to obtain full exemption from taxation on interest imposed by Spain, subject to the completion of procedural formalities.
Spanish Treaty Lender means, in relation to an Advance to a Borrower incorporated in Spain, a Lender that (a) is treated as a resident of a jurisdiction having a double taxation agreement with Spain which makes provision for full exemption from tax on payment of interest imposed by Spain, for the purposes of the relevant double taxation agreement, and (b) does not carry on a business in Spain through a permanent establishment with which that Lender’s participation in a Senior Finance Document is effectively connected;
Spanish Treaty Lender means in relation to a payment of interest by or in respect of a Spanish Borrower under any Loan Document, a Lender which: xxx.xx treated as a resident of a jurisdiction having a double tax agreement Spain which makes provision for full exemption for Tax imposed by Spain on interest payments and qualifies for such exemption on the basis its resident jurisdiction. lv.does not carry on a business in Spain through a permanent establishment with which that Lender's participation in the Loan is effectively connected; and
Examples of Spanish Treaty Lender in a sentence
Subject to paragraph (ii) below, a Treaty Lender (other than a Spanish Treaty Lender) and each Obligor which makes a payment to which that Treaty Lender is entitled shall co-operate in completing any procedural formalities necessary for that Obligor to obtain authorisation to make that payment without a Tax Deduction.
More Definitions of Spanish Treaty Lender
Spanish Treaty Lender means a Lender which is treated as a resident of a Treaty State for the purposes of a Treaty, is entitled to the benefits of such Treaty and does not carry on a business in Spain through a permanent establishment (as defined in the relevant treaty) with which that Lender’s participation in this Agreement is effectively connected, which subject to the completion of procedural formalities is entitled to be paid interest without the deduction of Spanish tax under that Treaty.
Spanish Treaty Lender means in relation to a payment of interest by or in respect of a Spanish Borrower under any Loan Document, a Lender which: is treated as a resident of a jurisdiction having a double tax agreement Spain which makes provision for full exemption for Tax imposed by Spain on interest payments and qualifies for such exemption on the basis its resident jurisdiction. does not carry on a business in Spain through a permanent establishment with which that Xxxxxx's participation in the Loan is effectively connected; and fulfills any other conditions which must be fulfilled under the relevant Spanish Treaty in order to benefit from full exemption from Tax imposed by Spain on interest including the completion of any necessary procedural formalities.
Spanish Treaty Lender means a Lender which: (a) is treated as a resident of a Spanish Treaty State for the purposes of the Spanish Treaty; (b) does not carry on a business in Spain through a permanent Exhibit 10.8 establishment with which that Xxxxxx’s participation in the DIP Term Facility is effectively connected; and (c) fulfils any conditions which must be fulfilled under the Spanish Treaty for tax residents of that Spanish Treaty State (including the completion of any procedural formalities) to obtain full exemption from Spanish taxation on interest payable to that Lender in respect of an advance under the DIP Term Facility.
Spanish Treaty Lender means in relation to a payment of interest by or in respect of a Spanish Borrower under any Loan Document, a Lender which:
Spanish Treaty Lender means a Lender who is treated as a resident for tax purposes in a jurisdiction having a double tax treaty in force with Spain, making provision for a full exemption from Spanish withholding taxes on interest, and which is entitled to receive interest under such double tax treaty without a deduction of Tax imposed by Spain and does not carry on a business in Spain through a permanent establishment therein with which such Lender’s interest in the relevant Loan is effectively connected. For the avoidance of doubt, a Lender with respect to a Spanish Loan Party that is a bank or other financial institution claiming the benefits of the Treaty between Spain and the United States of America dated February 22, 1990, shall not have the status of a Spanish Treaty Lender.
Spanish Treaty Lender means a Lender which: (a) is treated as a resident of a Spanish Treaty State for the purposes of the Spanish Treaty;(b) does not carry on a business in Spain through a permanent establishment with which that Lender’s participation in the DIP Term Facility is effectively connected; and (c) fulfils any conditions which must be fulfilled under the Spanish Treaty for tax residents of that Spanish Treaty State (including the completion of any procedural formalities) to obtain full exemption from Spanish taxation on interest payable to that Lender in respect of an advance under the DIP Term Facility.
Spanish Treaty Lender means a Lender who: