Capital Gains Tax. The Seller acknowledges and agrees that any capital gains tax in connection with the sale of the Shares contemplated hereunder shall be borne by the Seller alone, and the Seller shall fully indemnify the Purchaser Parties if CECEP Lux, Italsolar or any of the CECEP Lux Project Companies is required to pay or withhold any portion of such capital gains tax by any Tax authority due to this transaction.
Capital Gains Tax. Any capital gains tax imposed by any governmental authority on Sellers as a result of this Agreement shall be exclusively borne by Sellers and such cost is deemed by the parties as included in the Purchase Price provided for by Section 1(b).
Capital Gains Tax. The Seller acknowledges and agrees that any capital gains tax in connection with the sale of the HD Commerce Shares contemplated hereunder shall be borne by the Seller alone, and the Seller shall fully indemnify the Purchaser if Purchaser is required to pay or withhold any portion of such capital gains tax by any Tax authority due to this transaction.
Capital Gains Tax. Any capital gains realized as a result of the conveyance or transfer of any rights under this Agreement or of the Akyem Mining Lease shall be subject to Taxes and Duties under Law provided that in the case of (i) capital gains realized by Golden Ridge the provisions of Section 5.1 shall apply; and (ii) no Taxes and Duties shall be imposed upon capital gains accruing to or derived
Capital Gains Tax. 7.1 If each of the capital assets of the Company were disposed of for a consideration equal to the book value of that asset in, or adopted for the purpose of, the Audited Accounts, 77 no liability to corporation tax on chargeable gains would arise by reason of any such disposal and for the purpose of determining whether any such taxation would arise there shall be disregarded any relief or allowance available to the Company other than amounts falling to be deducted in calculating the amount liable to Taxation.
Capital Gains Tax. (a) Within ten (10) days following the Closing, Buyer shall pay the Capital Gains Tax with respect to the Closing Purchase Price and the Foreign Advisor Fees, withheld by Buyer pursuant to Section 2.3(b)(i)(A), to the applicable Panamanian Governmental Body (Dirección General de Ingresos – Ministerio de Economía y Finanzas), such payment to include the filing of the Deed of Transfer. Buyer shall deliver to Sellers the original receipt of payment of such Capital Gains Tax within two (2) Business Days of such payment.
Capital Gains Tax. Capital gains and losses of residents of South Africa on the disposal of Notes are subject to capital gains tax. Any discount or premium on acquisition which has already been treated as interest for income tax purposes, under section 24J of the Income Tax Act will not be taken into account when determining any capital gain or loss. Under section 24J(4A) of the Income Tax Act a loss on disposal will, to the extent that it has previously been included in taxable income (as interest), be allowed as a deduction from the taxable income of the holder when it is incurred and accordingly will not give rise to a capital loss. In terms of section 24J of the Income Tax Act, an adjusted loss on transfer or redemption will, to the extent that it has previously been included in the taxable income of the holder, be allowed as a deduction from the taxable income of the holder when it is incurred during the year of assessment in which the transfer or redemption takes place, and accordingly will not give rise to a capital loss. Capital gains tax under the Eighth Schedule to the Income Tax Act will not be levied in relation to Notes disposed of by a person who is not a resident of South Africa unless the Notes disposed of are attributable to a permanent establishment of that person. Purchasers are advised to consult their own professional advisers as to whether a disposal of Notes will result in a liability to capital gains tax. Withholding Tax A final withholding tax on interest which is levied at the rate of 15% applies to interest payments made from a South African source to foreign persons (i.e. non-residents), subject to certain exemptions (see below). South Africa is also a party to double taxation treaties that may provide full or partial relief from withholding tax on interest, provided that certain requirements are met. The available exemptions apply in respect of the instrument giving rise to the interest, to the foreign person receiving the interest, or to the person liable for the interest (i.e. the Issuer). Regarding the exemptions applicable in respect of the instrument, an amount of interest is exempt if it is paid to a foreign person in terms of “listed debt”, being debt listed on a “recognised exchange”, as defined in terms of paragraph 1 of the Eight Schedule to the Income Tax Act. The Notes may be listed on a recognised exchange. Thus, to the extent that the Notes remain listed on that exchange (and to the extent that that exchange remains a recognised exc...
Capital Gains Tax. A farmout involves the disposal of assets by the farmor to the farmee, and a corresponding acquisition by the farmee. As such, it is a transaction which may result in capital gains tax (CGT) for the farmor and the creation of a cost base of the relevant assets for the farmee. Shortly after the introduction of CGT, these matters were considered by the Commissioner of Taxation in Income Tax Ruling 27 Sections 40-30(2) and 40-80(1). 28 For an analysis of the impact of these rules, and other new tax measures, see R Henderson, C Franchina and X Xxxxxxx, “Buying and Selling Petroleum Interests – Impact of Tax Consolidation and Other Tax Reform Measures” (2005) APPEA Journal 643. 29 Subdivision 40-D. This appears now to apply to mining information although TR98/3 (see below) had ruled that such information is not property and therefore the balancing adjustment provisions in subdiv 330-480 (now repealed) did not apply to it.
Capital Gains Tax. Any gains from the disposal of immovable property shall be taxed in the country where the immovable property is situated. Any gains from the disposal of shares are taxable in the country in which the seller is located.
Capital Gains Tax. If the property is acquired prior to 31st December 2014 and is held for 7 years or more the gain attributable to the 7 year period will be exempt from Capital Gains Tax (CGT). We recommend that interested parties satisfy themselves in relation to CGT and taxation matters relating to the property generally and seek advice from their accountant or tax advisor. Investment Summary • Prime location on Level 2 extension and opposite H&M • Well configured retail unit • Excellent quality tenant • Excellent rental growth prospects • Very favourable CGT provisions apply to the purchase completed prior to 31st December 2014 Solicitors Xxxxxxx Xxxxx Xxxxx Xxxxx Xxxxxx South Bank House, Xxxxxx St, Dublin 4 Telephone: (00) 000 0000. Pricing We are guiding €1,400,000 subject to contract/contract denied. A purchase at this level would produce an income yield of 6.84% after allowance for normal acquisition costs of 4.46%. No Contract Note our client is not obliged to accept the highest offer received and as usual no contract shall exist or be deemed to exist until such time as formal contracts have been executed and exchanged and deposit paid. These details do not form part of an offer or contract.
