TIOPA definition

TIOPA means the Taxation (International and Other Provisions) ▇▇▇ ▇▇▇▇;

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TIOPA means the UK Taxation (International and Other Provisions) ▇▇▇ ▇▇▇▇.

TIOPA means the Taxation (International and Other Provisions) Act 2010.

Examples of TIOPA in a sentence

• Part 9A of TIOPA imposes a charge to tax on chargeable profits, affecting any UK resident Company with an interest of 25 per cent or more (including the interests of associated or connected persons) in the profits of a non-UK resident company provided no statutory exemptions apply.

• Special tax rules apply to investments made in an offshore fund within the meaning of Part 8 of the Taxation (International and Other Provisions) ▇▇▇ ▇▇▇▇ ("TIOPA").

• If, for any year during the APA term, the Taxpayer does not comply with the terms and conditions of this APA, or the Critical Assumptions (as defined in Clause 6 below) cease to be valid, HMRC may (subject to clause 9 below) revoke this APA and S.221 TIOPA 2010 shall apply.

• The Company has retained sufficient information, contemporaneous documents and records to enable it to comply with, or establish that it is not subject to the operation of Part 4 TIOPA 2010 or any similar legislation in any jurisdiction outside the United Kingdom.

• There are no circumstances in which Part 4 of TIOPA 2010 or any other rule or provision could apply causing any Tax Authority to make an adjustment to the terms on which such transaction or arrangement is treated as being made for Tax purposes.

• HMRC may also revoke this agreement if, after the date of the agreement, Part 4 TIOPA 2010 or the transfer pricing guidelines as defined in Section 164(4) TIOPA 2010 are either amended or repealed and this would have an effect on the approach to pricing within this agreement.

• Moreover, for so long as the Company is a UCITS, then there may be further protection against the Company becoming UK tax resident pursuant to section 363A Taxation (International and Other Provisions) ▇▇▇ ▇▇▇▇ ("TIOPA").

• The terms and conditions of this APA may also be modified or amended upon the agreement of the Parties, subject to the terms of any bilateral/multilateral agreement Where the conditions of S.226 TIOPA 2010 (Annulment of agreement for misrepresentation) apply the agreement is to be treated as never made.

• Part 9A of TIOPA contains provisions which subject certain United Kingdom resident companies to corporation tax on chargeable profits of companies not so resident in which they have an interest.

• For PE cases: HMRC may revoke this Agreement if, after the date of this agreement, Chapter 4 of Part 2 CTA 2009, S43 TIOPA 2010, or Chapter 2 Part 24 CTA 2010 are amended or repealed and this would have an effect on the approach to pricing within this agreement.

More Definitions of TIOPA

TIOPA the Taxation (International and Other Provisions) A▇▇ ▇▇▇▇;

TIOPA means the Taxation (International and Other Provisions) Act 2010

TIOPA means the Tax (International and Other Provisions) ▇▇▇ ▇▇▇▇; and "TMA" means the Tax Management ▇▇▇ ▇▇▇▇

TIOPA has the meaning given to it in Clause ‎12.6;

TIOPA means the Taxation (International and Other Provisions) Act zoro. "Transition Services Agreement" means the transition services agreement between the Company and the relevant entity or entities of the Seller's Group in order to facilitate the ordeily continuation of the business of the Group after Closing with a scope and in a form to be agreed between the Buyer and the Seller prior to Closing, but, for the avoidance of doubt, with a duration of no more than three years. "Transaction Expenses" means costs, fees, expenses and other amounts owing to third parties incurred prior to or in connection with Closing by the Group or for which the Group åtherwise has the obligation to pay relating to, arising out of or in connection with planning, structuring, negotiating or consummating the transactions contemplated hereunder to the extent.rnpiid ai of immediately prior to Closing, including (a) fees and disbursements of attorneys, investment bankers, accountants and other professional advisors which, in each case, have not been paid as of Closing. The Parties have agreed that the value ofthe stay bonuses made or to be made by the Group in connection with the signing of this Agreement and/or Closing to those employees of the Group agreed between the Seller and the Buyer, together with the Group's portion of any withholding taxes applicable to such stay bonuses and any employer's national insurance contributions thereon, (collectively, the "Stay Bonuses") ▇▇▇▇▇ not be considered Transaction Expenses or Indebtedness or the like. For the avoidance of doubt, Transaction Expenses shall not include deferred Tax liabilities or Taxes payable (other than irrecoverable VAT incurred on such Transaction Expenses), and any 1385198o.4 01 4 -46s5-07 27 I I 1 /EU ROPE

TIOPA means the Taxation (International and Other) Provisions A▇▇ ▇▇▇▇. References to the “Company” shall include each of the Subsidiaries.