Base Erosion and Profit Shifting Sample Clauses

Base Erosion and Profit Shifting. 2. As regards to the application of this Agreement at any time by a Competent Authority of a Jurisdiction, any term not otherwise defined in this Agreement will, unless the context otherwise requires or the Competent Authorities agree to a common meaning (as permitted by domestic law), have the meaning that it has at that time under the law of the Jurisdiction applying this Agreement, any meaning under the applicable tax laws of that Jurisdiction prevailing over a meaning given to the term under other laws of that Jurisdiction.
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Base Erosion and Profit Shifting. The law and any other rules or customary practice relating to tax, or its interpretation in relation to the Jersey Issuers, its assets and any investment of the Jersey Issuers may change during its life. In particular, both the level and basis of taxation may change. In particular, the OECD's on- going global Base Erosion and Profit Shifting project which intends to achieve a multinational framework on corporate taxation could substantially affect the tax treatment of the Jersey Issuers. Additionally, the interpretation and application of tax rules and customary practice to the Jersey Issuers, its assets and investors by any taxation authority or court may differ from that anticipated by the Jersey Issuers. Both could significantly affect returns to investors. Considerations regarding increased regulation The financial markets are encountering the increased involvement of governmental and regulatory authorities in the financial sector and in the operation of financial institutions and products offered and/or arranged by them. In particular, governmental and regulatory authorities in a number of jurisdictions have imposed stricter regulatory controls around certain financial activities and/or have indicated that they intend to impose such controls in the future. The United States of America, the European Union and other jurisdictions are actively considering or are in the process of implementing various reform measures covering, among other things, derivative transactions and the offering of structured products and other financial investments and instruments. Such regulatory changes and the method of their implementation may have a significant impact on the operation of the financial markets and may also effect the value, characterisation and/or treatment of Securities issued by the Issuer and/or the characterisation and/or treatment of any of the transactions or agreements relating thereto. Certain of the regulatory developments may also impose obligations on the Issuer, the Swap Counterparty, the Agents and/or other applicable parties including, without limitation and among other things, in respect of derivative transactions (such as the reporting of transactional and other information relating to derivative transactions to trade repositories in various jurisdictions, the provision of collateral in certain circumstances mandated by such regulations and, potentially, the mandated clearing of certain derivative transactions). The ability of the Issuer, the ...
Base Erosion and Profit Shifting. (BEPS) related issue will be address each year at a workshop. The BEPS package includes 15 action points that address various forms of tax avoidance, including transfer pricing, and has been endorsed by over 135 countries and jurisdictions worldwide. Policymakers from SEE will gain a comprehensive understanding, with a particular focus on transfer pricing standards. The workshop will be designed in partnership with the OECD.
Base Erosion and Profit Shifting. The law and any other rules or customary practice relating to tax, or its interpretation in relation to the Issuers, their assets and any investment of the Issuers may change during their life. In particular, both the level and basis of taxation may change. In particular, the OECD's on-going global Base Erosion and Profit Shifting project which intends to achieve a multinational framework on corporate taxation could substantially affect the tax treatment of any of the Issuers. Additionally, the interpretation and application of tax rules and customary practice to all of the Issuers, their assets and investors by any taxation authority or court may differ from that anticipated by the Issuers. Both could significantly affect returns to investors.

Related to Base Erosion and Profit Shifting

  • Tax Examinations Abroad 1. A Contracting Party may allow representatives of the competent authority of the other Contracting Party to enter the territory of the first-mentioned Party to interview individuals and examine records with the written consent of the persons concerned. The competent authority of the second-mentioned Party shall notify the competent authority of the first-mentioned Party of the time and place of the meeting with the individuals concerned.

  • Group Health Benefit Plans, Carrier and Premiums 7.1.1 When enrolment and other requirements for group participation in various plans have been met, the Employer will sponsor such plans to the portion agreed upon and such sponsorship shall not exceed that which is authorized or accepted by the benefit agency.

  • Corrective Maintenance ‌ Corrective Maintenance as referred to herein shall mean Repair and/or Replacement Services. For the purposes of evaluating whether Corrective Maintenance qualifies as either Minor or Major Corrective Maintenance, the Contractor shall calculate the total cost of the Corrective Maintenance in accordance with the following formulas, and the cost shall be calculated per Repair Item which shall be compared to the Major/Minor Corrective Maintenance Threshold listed in Table 2. Total Cost of Repair Item = (Labor Cost) + (Material Cost) Where: Labor Cost = (H) x [(1 + LMR/100) x (PWR + SB)] H = Number of labor hours needed to complete the Corrective Maintenance LMR = Labor Markup Rate (%) PWR = Prevailing Wage Rate SB = Supplemental Benefits Material Cost = (Cost of Materials) x (1 + MMR/100) Where: MMR = Materials Markup Rate (%) The Contractor’s Monthly Maintenance fee shall include, but is not necessarily limited to, all preventative maintenance service and all corrective maintenance service with a total cost (labor and materials) less than or equal to the thresholds listed in the following table, which shall be referred to as ‘Minor Corrective Maintenance: Table 2: Corrective Maintenance Thresholds Lot(s) Type of Equipment Major/Minor Corrective Maintenance Threshold 1 Gearless Traction Elevators $2500 1 Geared Traction Elevators $2500 2 Hydraulic Elevators $1000 3 Escalators $2500 4 Wheelchair Lifts $500 4 Stage Lifts $500 4 Dumbwaiters $500 Corrective maintenance work that has a Total Cost that exceeds these thresholds shall be considered Major Corrective Maintenance. The Contractor shall justify all costs for Major Corrective Maintenance to the Authorized User’s satisfaction, and for Repair Items that qualify as Major Corrective Maintenance the Contractor shall be compensated for the full cost of the work unless the corrective maintenance is determined to be the result of the Contractor’s negligence, in which case the Contract shall not be additionally compensated. Prior to performing any Major Corrective Maintenance, the Contractor shall submit a Cost Proposal to the Authorized User for approval. The Cost Proposal shall be a maximum, not to exceed price; shall include all labor and material costs associated with the Major Corrective Maintenance and shall be calculated on a per item basis (like items shall not be combined in the calculation). Upon approval, a letter authorizing the work will be issued by the Authorized User and a copy of such letter must accompany the invoice for the Major Corrective Maintenance services. Please note that if subcontractors are to be used, the requirements of Section 2.22 ‘Subcontracting of Work’ shall be met.

  • Mileage Measurement Where required, the mileage measurement for LIS rate elements is determined in the same manner as the mileage measurement for V&H methodology as outlined in NECA Tariff No. 4.

  • Workplace Safety Insurance Benefits (WSIB) Top Up Benefits If the employee is in a class of employees that, on August 31, 2012, was entitled to use unused sick leave credits for the purpose of topping up benefits received under the Workplace Safety and Insurance Act, 1997;

  • SAVINGS/FORCE MAJEURE A force majeure occurrence is an event or effect that cannot be reasonably anticipated or controlled. Force majeure includes, but is not limited to, acts of God, acts of war, acts of public enemies, strikes, fires, explosions, actions of the elements, floods, or other similar causes beyond the control of the Contractor or the Commissioner in the performance of the Contract which non- performance, by exercise of reasonable diligence, cannot be prevented. Contractor shall provide the Commissioner with written notice of any force majeure occurrence as soon as the delay is known. Neither the Contractor nor the Commissioner shall be liable to the other for any delay in or failure of performance under the Contract due to a force majeure occurrence. Any such delay in or failure of performance shall not constitute default or give rise to any liability for damages. The existence of such causes of such delay or failure shall extend the period for performance to such extent as determined by the Contractor and the Commissioner to be necessary to enable complete performance by the Contractor if reasonable diligence is exercised after the cause of delay or failure has been removed. Notwithstanding the above, at the discretion of the Commissioner where the delay or failure will significantly impair the value of the Contract to the State or to Authorized Users, the Commissioner may:

  • Contribution Formula Health Coverage a. Faculty Member Coverage. For faculty member health coverage for the 2018 2022 and 2019 2023 plan years, the Employer contributes an amount equal to ninety-five percent (95%) of the employee- only premium of the Minnesota Advantage Health Plan (Advantage).

  • Emergency Escalation Escalation is strictly for purposes of notifying and investigating possible or potential issues in relation to monitored services. The initiation of any escalation and the subsequent cooperative investigations do not in themselves imply that a monitored service has failed its performance requirements. Escalations shall be carried out between ICANN and Registry Operators, Registrars and Registry Operator, and Registrars and ICANN. Registry Operators and ICANN must provide said emergency operations departments. Current contacts must be maintained between ICANN and Registry Operators and published to Registrars, where relevant to their role in escalations, prior to any processing of an Emergency Escalation by all related parties, and kept current at all times.

  • Revenue Metering The Connecting Transmission Owner’s revenue metering will be located on the generator side of the 115kV breaker at the Xxxxx Solar Collector Substation and will consist of: • three (3) combination current/voltage transformer (“CT/VT”) units (manufacturer and model ABB/Xxxxxxx KXM-550, GE Grid Solutions KOTEF 000.XX, or other equivalent specified by Connecting Transmission Owner); and • one (1) revenue meter. The ratios of the CTs and VTs will be provided by Connecting Transmission Owner upon its review of the Interconnection Customer’s design documents. (Note: Connecting Transmission Owner’s revenue metering CTs and VTs cannot be used to feed the Interconnection Customer’s check meter.) SERVICE AGREEMENT NO. 2556

  • SAVINGS/FORCE MAJEURE A Force Majeure occurrence is an event or effect that cannot be reasonably anticipated or controlled and is not due to the negligence or willful misconduct of the affected party. Force Majeure includes, but is not limited to, acts of God, acts of war, acts of public enemies, terrorism, strikes, fires, explosions, actions of the elements, floods, or other similar causes beyond the control of the Contractor or the Commissioner in the performance of the Contract where non- performance, by exercise of reasonable diligence, cannot be prevented. The affected party shall provide the other party with written notice of any Force Majeure occurrence as soon as the delay is known and provide the other party with a written contingency plan to address the Force Majeure occurrence, including, but not limited to, specificity on quantities of materials, tooling, people, and other resources that will need to be redirected to another facility and the process of redirecting them. Furthermore, the affected party shall use its commercially reasonable efforts to resume proper performance within an appropriate period of time. Notwithstanding the foregoing, if the Force Majeure condition continues beyond thirty (30) days, the Parties shall jointly decide on an appropriate course of action that will permit fulfillment of the Parties’ objectives hereunder. The Contractor agrees that in the event of a delay or failure of performance by the Contractor, under the Contract due to a Force Majeure occurrence:

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