Company Residence. Each Group Company has been resident for tax purposes in its country of incorporation and has not been resident anywhere else at any time since its incorporation and will be so resident at Closing. For the avoidance of doubt, references to residence in this paragraph shall be construed as references to residence as determined by the local law of the jurisdiction or jurisdictions concerned and not by reference to the provisions of any relevant double taxation treaty or convention.
Company Residence. Each Group Company has been resident for Taxation purposes in its place of incorporation and nowhere else at all times since its incorporation. No Group Company has been liable to pay Taxation on its net income, profit or gains to any Tax Authority outside its jurisdiction of incorporation.
Company Residence. The Company has been resident for tax purposes in Seychelles and nowhere else at all times since its incorporation and will be so resident at Closing.
Company Residence. Each of the Target Group Companies is resident for Taxation purposes in the jurisdiction specified in Part 2 of the Schedule and has not been resident anywhere else at any time since its incorporation. For the avoidance of doubt, references to residence in this paragraph 4 shall be construed as references to residence as determined by the local law of the jurisdiction or jurisdictions concerned and not by (unless required by such local law) reference to the provisions of any relevant double tax agreement, treaty or convention.
Company Residence. Each Group Company has been resident for Taxation purposes in its place of incorporation and nowhere else at all times since its incorporation and will be so resident at Closing.
Company Residence. Each UK Company has been resident for tax purposes in the United Kingdom and nowhere else at all times since its incorporation and will be so resident at Closing.
Company Residence. The Company has always been resident in the territory in which it was incorporated and has not been assessed to Tax in any other jurisdiction. The Company does not have a permanent establishment or other taxable presence in any jurisdiction other than that in which it was incorporated.
Company Residence. 14.1.1 Each Group Company has been resident for tax purposes in its jurisdiction of incorporation and has not been resident anywhere else at any time since its incorporation and will be so resident at Closing. For the avoidance of doubt, references to residence in this paragraph 14.1 will be construed as references to residence as determined by the local law of the jurisdiction or jurisdictions concerned and not by reference to the provisions of any relevant double taxation treaty or convention.
14.1.2 No Group Company has been treated as having a branch, agency, arrangement or permanent establishment in any jurisdiction other than its jurisdiction of incorporation.
Company Residence. Each Group Company has been resident for Tax purposes in its place of incorporation, and nowhere else, at all times since its incorporation, and will be so resident at Completion, and its place of incorporation is the only country whose Tax Authorities seek to charge Tax on the worldwide profits and gains of that Group Company, and no Group Company has ever paid Tax on income profits or gains to any Tax Authority in any other country.
Company Residence. The Company has always been resident in the territory in which it was incorporated and has never been resident in any other territory or treated as so resident for the purposes of any double Tax agreement. CLOSE COMPANY
(a) The Company is a close company as defined by section 414 of the TA.
(b) No loan, advance, release or payment has been made or consideration given or transaction effected by the Company falling within sections 419 to 422 (inclusive) of the TA.
(c) The Company has made no transfer of value within the meaning of the IHTA.
(d) There has been no alteration of the share capital of the Company within section 98 of the IHTA. INHERITANCE TAX
