Common use of Allocation of Deductions Clause in Contracts

Allocation of Deductions. To the extent permitted by applicable Tax Law, Income Tax deductions arising from exercises of compensatory options, settlement of restricted stock unit awards, or exercises, vesting or settlement of any other compensatory equity or equity-based award, in each case, with respect to EQT stock or SpinCo stock, and in each case following the External Distribution (such options, restricted share awards, restricted stock unit awards, and other compensatory equity or equity-based awards, collectively, “Compensatory Equity Interests”), shall be claimed (A) in the case of an EQT Group Employee, Former EQT Group Employee or EQT Non-Employee Director (an “EQT Comp Deduction”), solely by the EQT Group, and (B) in the case of a SpinCo Group Employee, Former SpinCo Group Employee or Transferred Director (a “SpinCo Comp Deduction”), solely by the SpinCo Group. To the extent that any EQT Comp Deduction may not be claimed under applicable Tax Law by a member of the EQT Group but may be claimed under applicable Tax Law by a member of the SpinCo Group, SpinCo shall (or shall cause the relevant member of the SpinCo Group to) claim such deduction. To the extent that any SpinCo Comp Deduction may not be claimed under applicable Tax Law by a member of the SpinCo Group but may be claimed under applicable Tax Law by a member of the EQT Group, EQT shall (or shall cause the relevant member of the EQT Group) to claim such deduction.