Tax Deduction Event means that an opinion of a recognised law firm of international standing has been delivered to the Issuer, stating that by reason of a change in French law or regulation, or any change in the official application or interpretation of such law, becoming effective after the Issue Date, the tax regime of any payments under the Notes is modified and such modification results in the part of the interest payable by the Issuer in respect of the Notes that is tax-deductible being reduced.
Tax Deduction Event means that the Issuer has obtained an opinion in writing from a reputable firm of lawyers of good standing to the effect that interest payments under the Securities were, but are or will no longer be, tax-deductible by the Issuer for Dutch corporate income tax purposes by reason of:
Tax Deduction Event means that the Borrower has obtained an opinion in writing from a reputable firm of tax advisors of good standing (pre-approved by the Majority Lenders, such approval not unreasonably to be withheld), a decision of the Dutch tax authorities and/or a court ruling to the effect that interest payments under any of the Loans were, but are or will no longer be, tax-deductible by the Borrower for Dutch corporate income tax purposes by reason of:
Examples of Tax Deduction Event in a sentence
Subject to Condition 6.6, the Capital Securities may be redeemed at the option of the Issuer in whole, but not in part, at any time, on giving not less than 30 nor more than 60 days’ notice to the Securityholder in accordance with Condition 11, (which notice shall be irrevocable, subject to Condition 4C, and shall specify the date fixed for redemption), following the occurrence of a Tax Deduction Event.
The Trustee shall be entitled, without liability to any person, to accept such certification and, in the case of a Tax Deduction Event, opinion referred to in the definition thereof as sufficient evidence that a Tax Deduction Event or a Rating Agency Event, as the case may be, has occurred, in which event it shall be conclusive and binding on the Noteholders.
The Borrower may, upon the occurrence of a Rating Event, a Tax Deduction Event or a Withholding Tax Event, at any time, without the consent of the relevant Lenders, either: (a) substitute the Loans (in full) for; or (b) vary the terms of the Loans with the effect that the Loans remain or become, as the case may be, a Qualifying Loan.
Call Options:[Issuer Call] [Tax Deduction Event] [Accounting Event] [Rating Event] [Gross-up Event] [Repurchase Event][Change of Control Event] [(see paragraph[s] [18]/[19]/[20]/[21]/[22]/[23]below)] [Not Applicable]12.
Tax Deduction Event- Principal:Applicable PROVISIONS RELATING TO ANY INTEREST AMOUNT, THE REDEMPTION AMOUNT AND ANY ASSET AMOUNT DELIVERABLE IN RELATION TO THE NOTES13.
More Definitions of Tax Deduction Event
Tax Deduction Event means the occurrence of an event as a result of which interest payments under the Securities were, but are or will no longer be, tax-deductible by the Issuer for Dutch corporate income tax purposes by reason of:
Tax Deduction Event means that by reason of any change in French laws or regulations, or any political subdivision or any authority thereof or therein having power to tax, or any change in the application or official interpretation of such laws or regulations becoming effective on or after the Issue Date, the tax regime applicable to any interest payment under the Notes is modified and such modification results in the amount of the interest payable by the Issuer under the Notes that is tax- deductible by the Issuer for French corporate income tax (impôts sur les bénéfices des sociétés) purposes being reduced, provided that the due date for redemption of the Notes of which notice hereunder may be given in respect of a Tax Deduction Event shall be no earlier than the latest practicable date on which the Issuer could make such payment with interest payable being so tax deductible to the same extent as it was on the Issue Date;A “Tax Gross-Up Event” shall occur if the Issuer would on the next payment of principal or interest in respect of the Notes be prevented by French law from making payment to the Couponholders of thefull amount then due and payable, notwithstanding the undertaking to pay additional amounts contained in Condition 7.2;
Tax Deduction Event means (a) that as a result of a Tax Law Change, interest paid by the Issuer on the Notes would no longer, or within 90 days of such change or proposed change will no longer, be fully deductible (or the entitlement to make such deduction shall be materially reduced or materially delayed) by the Issuer for corporate income tax purposes; and/or (b) that, as a result of a Tax Law Change and the Notes being held by the Holders thereof, the Issuer (or any intra-group borrower under back-to-back lending arrangements within the BAM Group) (as applicable) would no longer, or within 90 days of such change or proposed change will no longer, be able to surrender to or receive from companies with which it is grouped for tax purposes under the laws or regulations of the United Kingdom or Canada (or with which it would be grouped but for any Tax Law Change), losses or other amounts which can be set against the recipient company’s profits (or the amounts capable of being surrendered and set against the recipient company’s profits or the timing of surrender or set off are materially reduced or materially delayed), in either case, as determined in the reasonable opinion of the Issuer and provided that the foregoing cannot be avoided by the Issuer (or intra-group borrower under back-to-back lending arrangements within the BAM Group) (as applicable) taking reasonable measures available to it, where references in this definition to the United Kingdom shall be deemed also to refer to any other jurisdiction or relevant authority thereof in which any successor issuer of the Notes is incorporated (except that as regards any such jurisdiction, the words “which in each case becomes, or would become, effective on or after the Issue Date” as used in the definition of Tax Law Change shall be replaced with the words “becomes effective after, and has not been announced on or before, the date on which the successor issuer, as applicable, is substituted for the Issuer (or its successor)”). For the purposes of the definition of Tax Deduction Event, being “grouped for tax purposes” with another company includes, for the avoidance of doubt and without limitation, being a member of the same “group of companies” as the other company, any “consortium condition” being met in respect of the other company or any other relationship sufficient to allow a surrender of losses or other amounts between the two companies for the purposes of Part 5 of the Corporation Tax Axx 0000 of the United Kingdom.
Tax Deduction Event means any change in the French laws or regulations, or any political subdivision therein or any authority thereof or therein having power to tax, or any change in the application or official interpretation of such laws or regulations becoming effective on or after 20 March 2014, which would cause the tax regime applicable to any interest payment under the Notes to be modified and such modification would result in the amount of the interest payable by the Issuer under the Notes that is tax-deductible by the Issuer for French corporate income tax (impôts sur les bénéfices des sociétés) purposes to be reduced.
Tax Deduction Event means (a) that as a result of a Tax Law Change interest paid by the Company on the Non-Call 5.25 Notes or the Non-Call 10 Notes or interest paid by the Guarantor pursuant to the Guarantee would no longer, or within 90 days of such change or proposed change will no longer, be fully deductible (or the entitlement to make such deduction shall be materially reduced or materially delayed) by the Company or the Guarantor (as applicable) for corporate income tax purposes; and/or (b) that as a result of a Tax Law Change and (i) the Non-Call 5.25 Notes being held by the Holders, (ii) the Non-Call 10 Notes being held by the Holders, or (iii) the Non-Call 5.25 or the Non-Call 10 Notes being held by the Holders together with the Other Hybrid Capital Notes being held by the holders thereof, the Company or the Guarantor (or any intra-group borrower under back-to-back lending arrangements within the BP Group) (as applicable) would no longer, or within 90 days of such change or proposed change will no longer, be able to surrender to or receive from companies with which it is grouped for tax purposes (or with which it would be grouped but for any Tax Law Change), losses or other amounts which can be set against the recipient company’s profits (or the amounts capable of being surrendered and set against the recipient company’s profits or the timing of surrender or set off are materially reduced or materially delayed), in either case, as determined in the reasonable opinion of the Company or the Guarantor (as applicable) and provided that the foregoing cannot be avoided the Company or the Guarantor, as the case may be, taking reasonable measures available to it, where references in this definition to the United Kingdom shall be deemed also to refer to any other jurisdiction or relevant authority thereof in which any successor issuer or guarantor of the Notes is incorporated (except that as regards any such jurisdiction, the words “which in each case becomes, or would become, effective on or after the Issuance Date” as used in the definition of Tax Law Change shall be replaced with the words “becomes effective after, and has not been announced on or before, the date on which the successor issuer or guarantor, as applicable, is substituted for the Company (or its successor) or the Guarantor (or its successor), as applicable)). For the purposes of the definition of Tax Deduction Event: Being “grouped for tax purposes” with another company includes, for the avoidance of doubt an...
Tax Deduction Event means (a) that as a result of a Tax Law Change interest paid by BP Capital U.K. on the Non-call 5.25 Notes or the Non-Call 10 Notes or interest paid by BP pursuant to the Guarantee would no longer, or within 90 days of such change or proposed change will no longer, be fully deductible (or the entitlement to make such deduction shall be materially reduced or materially delayed) by BP Capital U.K. or BP (as applicable) for corporate income tax purposes; and/or (b) that, as a result of a Tax Law Change and (i) the
Tax Deduction Event means (a) that as a result of a Tax Law Change, other than an Excluded Change, interest paid by the Company on the Notes or interest paid by the Guarantor pursuant to the Guarantee would no longer, or within 90 days of such change or proposed change will no longer, be fully deductible (or the entitlement to make such deduction shall be materially reduced or materially delayed) by the Company or the Guarantor (as applicable) for corporate income tax purposes; and/or (b) that as a result of a Tax Law Change and (i) the Notes being held by the Holders, or (ii) the Notes being held by the Holders together with the Other Hybrid Capital Notes being held by the holders thereof, the Company or the Guarantor (or any intra-group borrower underback-to-back lending arrangements within the BP Group) (as applicable) would no longer, or within 90 days of such change or proposed change will no longer, be able to surrender to or receive from companies with which it is grouped for tax purposes (or with which it would be grouped but for any Tax Law Change), losses or other amounts which can be set against the recipient company’s profits (or the amounts capable of being surrendered and set against the recipient company’s profits or the timing of surrender or set off are materially reduced or materially delayed), in either case, as determined in the reasonable opinion of the Company or the Guarantor (as applicable) and provided that the foregoing cannot be avoided the Company or the Guarantor, as the case may be, taking reasonable measures available to it, where references in this definition to the United Kingdom shall be deemed also to refer to any other jurisdiction or relevant authority thereof in which any