BEPS. (a) To the extent that the Company incurs any Tax that makes the effective Tax rate of the Company and its Subsidiaries (if any) and branches in Ireland (assessed on a standalone basis) for any applicable period exceed 15% under any Applicable Law in Ireland based on the GloBE Rules solely as a result of the Company and/or any Subsidiary or branch being a Constituent Entity of an MNE Group of which Intel Member or any of its Affiliates (other than the Company or any of its Subsidiaries) is the Ultimate Parent Entity (a “Pillar 2 Tax”), then Intel Member shall (A) promptly notify Co-Investor Member upon becoming aware of such Pillar 2 Tax and (B) pay the Company and its Subsidiaries the amount required to ensure that Co-Investor Member shall receive the same amount as it would have received on an “after-tax basis” under this Agreement had no such Pillar 2 Tax been incurred. For the avoidance of doubt, any such payment made by Intel Member pursuant to this Section 13.15(a) shall constitute an Additional Intel Contribution.
BEPS why you’re taxed more than a multinational, OECD Insights (Feb. 13, 2013), xxxx://xxxxxxxxxxxx.xxx/2013/02/13/beps-why-youre-taxed-more-than-a-multinational.
