Common use of Allocation of Foreign Income Tax and Foreign Other Tax Relating to Separate Returns Clause in Contracts

Allocation of Foreign Income Tax and Foreign Other Tax Relating to Separate Returns. (i) ParentCo shall be responsible for any and all Foreign Income Taxes or Foreign Other Taxes that, following the Distribution Date, are required to be paid with respect to, or required to be reported on, any ParentCo Separate Return (including any Foreign Income Tax of ParentCo or any member of the ParentCo Group imposed by way of withholding by a member of the SpinCo Group), and including any increase in such Tax as a result of a Final Determination, for all Tax Periods. (ii) SpinCo shall be responsible for any and all Foreign Income Taxes or Foreign Other Taxes that, following the Distribution Date, are required to be paid with respect to, or required to be reported on, any SpinCo Separate Return (including any Foreign Income Tax of SpinCo or any member of the SpinCo Group imposed by way of withholding by a member of the ParentCo Group), and including any increase in such Tax as a result of a Final Determination, for all Tax Periods.