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 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. 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. (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.
(b) Within ten (10) days following the payment of any Additional Payment Amount by Buyer pursuant to Section 2.4(d)(i), Buyer shall pay the Capital Gains Tax in respect of such Additional Payment Amount to the applicable Panamanian Governmental Body (Dirección General de Ingresos – Ministerio de Economía y Finanzas). 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. 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.
7.2 The Company has not taken part in any transaction in respect of which section 176 TCGA 1992 could apply to reduce any allowable loss.
7.3 No charge to Tax will arise under ss 178-181 (inclusive) TCGA 1992 (company ceasing to be member of a group) on the sale of the Company pursuant to this Agreement or on the sale of the Company at any time in the six years following the date of this Agreement.
7.4 The Company does not own any shares or securities acquired as a "new holding" under the provisions of Sections 126 to 130 (inclusive) as extended by Xxxxxxxx 000, 000, xxx 000 XXXX 0000.
7.5 The Company has not made any such election as is referred to in Section 35(5) TCGA 1992 (31 March 1982 rebasing) nor has it been treated by paragraph 8 Schedule 3 TCGA 1992 as having made an election that all disposals shall fall outside section 35 TCGA 1992.
7.6 The Company has not engaged in any transactions which may hereafter result in an adjustment being made, under Sections 29, 30, 31, 32, 33 or 34 TCGA 1992 of the consideration received on any future disposal (value shifting).
7.7 The Company has not made a claim or election under any of the following:-
(a) Section 279 (foreign assets:delayed remittance), Section 23 (capital sums:compensation and insurance money), Section 24 (assets lost or destroyed or whose value becomes negligible) or Section 48 (consideration due after time of disposal) TCGA 1992; or
(b) Section 242 (small part disposals), Section 243 (disposal of authority with compulsory purchase powers), Section 244 (part disposal:consideration exceeding allowable expenditure), Section 247 (roll-over on compulsory acquisition), Section 152 or Section 153 (roll-over on replacement of business assets) or Section 161(3) (appropriation to trading stock) TCGA 1992; nor has any claim under those sections been made by any other company so as to affect the base cost of any of the Company's assets for the purpose of calculating chargeable gains.
7.8 The Compan...
Capital Gains Tax. According to article 13 of the DTT, gains derived by a resident of a contracting state from the alienation of immovable property referred to in the DTT and situated in the other contracting state, may be taxed in that other state. Gains from the disposal of shares which derive their value from immovable property may be taxed in the country where the property is located. Gains from the disposal of other shares may be taxed in the country of residency of the company – issuer of shares. It is worth mentioning that a Protocol to the DTT contains a specific provision according to which gains from the disposal of shares acquired at any time prior to 1 April 2017 will be taxable only in the country of residency of the seller of such shares. Gains from the alienation of other property- in particular ships or aircraft - are to be taxed only in the state of residence of the person which alienates such property.
Capital Gains Tax. Any capital gains realized as a result of the conveyance or transfer of any rights under this Agreement or of the Ahafo Mining Lease shall be subject to Taxes and Duties under Law provided that in the case of (i) capital gains realized by NGGL the provisions of Section 5.1 shall apply; and (ii) no Taxes and Duties shall be imposed upon capital gains accruing to or derived by NGGL or an Affiliate and arising out of the realisation of a chargeable asset from a merger, amalgamation, or re-organisation of NGGL or an Affiliate where the Affiliate (or Affiliates) that owns or controls all other Affiliates involved in such transactions will retain at least a 25% beneficial ownership interest in NGGL when the conveyance or transfer has been completed. For purposes of this Agreement “reorganization” shall mean an internal restructuring or reallocation of the ownership of NGGL such that ownership passes from one Affiliate to another.
Capital Gains Tax. If you are selling an investment property you will have to pay Capital Gains Tax. Depending on how you hold the property there is tax concession of 50% if you have owned the property for more than 12 months. The relevant date is the Contract Date not the Settlement Date. The application of Capital Gains Tax is too complicated for the general purposes of this guide. If you require specific advice, please contact your accountant. If you don’t have an accountant, the Qld Law Group can put you in touch with an accountant experienced in Capital Gains Tax. There is no fee payable to the Qld Law Group for this service and this is just another way the Qld Law Group gives you its complete conveyancing service. Typical conveyancing services leave you to deal with the confusing matter of Capital Gains Tax, not the Qld Law Group.
Capital Gains Tax. A Noteholder will not be subject to Irish taxes on capital gains provided that such Noteholder is neither resident nor ordinarily resident in Ireland and such Noteholder does not have an enterprise, or an interest in an enterprise, which carries on business in Ireland through a branch or agency or a permanent representative to which or to whom the Notes are attributable. If the Notes are comprised in a gift or inheritance taken from an Irish domiciled, resident or ordinarily resident disponer or if the donee/successor is resident or ordinarily resident in Ireland, or if any of the Notes are regarded as property situate in Ireland, the donee/successor may be liable to Irish capital acquisitions tax. As a result, a donee/successor may be liable to Irish capital acquisitions tax, even though neither the disponer nor the donee/successor may be domiciled, resident or ordinarily resident in Ireland at the relevant time. For as long as Iris is a qualifying company within the meaning of Section 110 TCA 1997, no Irish stamp duty will be payable on either the issue or transfer of Notes issued by Xxxx, provided that the money raised by the issue of the Notes is used in the course of Iris' business. Under EC Council Directive 2003/48/EC on the taxation of savings income, Member States are required, from 1st July, 2005, to provide to the tax authorities of another Member State details of payments of interest (or similar income) paid by a person within its jurisdiction to an individual resident in that other Member State. However, for a transitional period, Belgium, Luxembourg and Austria are instead required (unless during that period they elect otherwise) to operate a withholding system in relation to such payments (the ending of such transitional period being dependent upon the conclusion of certain other agreements relating to information exchange with certain other countries). A number of non-EU countries and territories including Switzerland have agreed to adopt similar measures (a withholding system in the case of Switzerland) with effect from the same date.
Capital Gains Tax. 6.4.1 The Company has not made any claim under Section 597 of the Taxes Consolidation Act, 1997, as respects the consideration for the disposal of or of its interest in any assets which are defined in the said Section 597 as "the old assets".
6.4.2 The Company has not made any such transfer as is referred to in Section 589 of the Taxes Consolidation Act, 1997, or received any asset by way of gift as mentioned in Section 978 of the Taxes Consolidation Act, 1997.
6.4.3 The Company has not been a party to or involved in any share for share exchange nor any scheme of reconstruction or amalgamation such as are mentioned in Sections 583 to 588, Section 600, Section 615 or Section 733 of the Taxes Consolidation Act, 1997, under which shares or debentures have been issued or any transfer of assets effected.
6.4.4 [The Company has not entered into any transaction which has, will or may give rise to a charge to tax under the provisions of Taxes Consolidation Act, 1997 or under the provisions of the Capital Acquisitions Tax Act, 1976.]
6.4.5 The Company has no liability by virtue of the provisions of Section 571 of the Taxes Consolidation Act, 1997.
6.4.6 The Company has not made any claim under Section 1005 of the Taxes Consolidation Act, 1997 and no tax liability has been deferred under any other provision of the Taxes Consolidation Act, 1997 including Sections 981 and 563(1) of the Taxes Consolidation Act, 1997.
6.4.7 The Company has not entered into any transactions which give rise to a liability under Sections 590, 616, 623, 625, 626 of the Taxes Consolidation Act, 1997. Nor has
