Allocation of Taxes Relating to Separate Returns. (i) Except as otherwise provided in Section 2.1(b)(iii), Xxxxxxxxx shall pay and be responsible for any and all Taxes due with respect to or required to be reported on (A) any Kellanova Separate Return (including any increase in such Tax as a result of a Final Determination) for all taxable periods and (B) any WKKC Separate Return (including any increase in such Tax as a result of a Final Determination) with respect to a taxable period ending on or before the Distribution Date.
(ii) Except as otherwise provided in Section 2.1(b)(iii), WKKC shall pay and be responsible for any and all Taxes due with respect to or required to be reported on any WKKC Separate Return (including any increase in such Tax as a result of a Final Determination) for all taxable periods other than taxable periods ending on or before the Distribution Date (excluding, for the avoidance of doubt, any Transaction Taxes allocated to the Kellanova Group pursuant to Section 2.3).
(iii) The Party that directly or indirectly owns real or personal property following the Distribution shall pay and be responsible for any real property, personal property or similar Taxes imposed with respect to such property.
Allocation of Taxes Relating to Separate Returns. Except as otherwise provided herein:
(i) Distributing shall pay and be responsible for any and all Taxes due with respect to or required to be reported on any Distributing Separate Return (including any increase in such Taxes as a result of a Final Determination) for all Tax Periods.
(ii) SpinCo shall pay and be responsible for any and all Taxes due with respect to or required to be reported on any SpinCo Separate Return (including any increase in such Taxes as a result of a Final Determination) for all Tax Periods.
Allocation of Taxes Relating to Separate Returns. (i) Lilly shall be responsible for any and all Taxes due with respect to or required to be reported on any Lilly Separate Return (including any increase in such Tax as a result of a Final Determination) for all Tax Periods.
(ii) The Company shall be responsible for any and all Taxes due with respect to or required to be reported on any Company Separate Return (including any increase in such Tax as a result of a Final Determination) for all Tax Periods.
Allocation of Taxes Relating to Separate Returns. (i) Pluto shall be allocated all Taxes due with respect to or required to be reported on (x) any Pluto Separate Return for any taxable period and (y) any Spinco Separate Return for any Pre-Distribution Period (including, in each case, any increase in such Tax as a result of a Final Determination).
(ii) Spinco shall be allocated any and all Taxes due with respect to or required to be reported on any Spinco Separate Return (including any increase in such Tax as a result of a Final Determination) for any Post-Distribution Period.
Allocation of Taxes Relating to Separate Returns. (i) Parent shall pay and be responsible for any and all Taxes due with respect to or required to be reported on any Parent Separate Return (including any increase in such Tax as a result of a Final Determination) for all taxable periods.
(ii) SpinCo shall pay and be responsible for any and all Taxes due with respect to or required to be reported on any SpinCo Separate Return (including any increase in such Tax as a result of a Final Determination) for all taxable periods (excluding, for the avoidance of doubt, any Transaction Taxes allocated to the Parent Group pursuant to Section 2.4).
Allocation of Taxes Relating to Separate Returns
