Common use of Control Rights Clause in Contracts

Control Rights. The party responsible under this Agreement for filing the relevant Income Tax Return shall control any audits by, disputes with, and administrative, judicial or other proceedings by or against taxing authorities related thereto. Subject to the preceding sentence, in the event an adverse determination may result in each party having responsibility for any amount of Income Taxes under this Agreement, each party shall be entitled to fully participate in that portion of the proceedings relating to the Income Taxes with respect to which it may incur liability hereunder. For purposes of this Section 9(d), the term "participation" shall include (i) participation in conferences, meetings or proceedings with any tax authority, the subject matter of which includes an item for which such party may have liability hereunder, (ii) participation in appearances before any court or tribunal, the subject matter of which includes an item for which a party may have liability hereunder and (iii) with respect to the matters described in clauses (i) and (ii), participation in the submission and determination of the content of the documentation, protests, memoranda of fact and law, briefs and the conduct of oral arguments and presentations.

Control Rights. The party responsible filing Party under this Agreement for filing the relevant Income Tax Return Section 6 shall control any audits byaudits, disputes withdisputes, and administrative, judicial or other proceedings by or against taxing authorities related theretoto Taxes with respect to which either Party may incur liability hereunder. Subject to the preceding sentence, in the event an adverse determination may result in each party Party having responsibility for any an amount of Income Taxes under this AgreementSection 6, each party Party shall be entitled to fully participate in that portion of the proceedings relating to the Income Taxes with respect to which it may incur liability hereunder. For purposes of this Section 9(d6.5(b), the term "participation" “participate” shall include (i) participation in conferences, meetings or proceedings with any tax Tax authority, the subject matter of which includes an item for which such party Party may have liability hereunder, (ii) participation in appearances before any court or tribunal, the subject matter of which includes an item for which a party such Party may have liability hereunder hereunder, and (iii) with respect to the matters described in the preceding clauses (i) and (ii), participation in the submission and determination of the content of the documentation, protests, memoranda of fact and law, briefs and briefs, and in the content and conduct of oral arguments and presentations.

Control Rights. The filing party responsible under this Agreement for filing the relevant Income Tax Return Section 9 shall control any audits byaudits, disputes withdisputes, and administrative, judicial or other proceedings by or against taxing authorities related theretoto Taxes with respect to which either party may incur liability hereunder. Subject to the preceding sentence, in the event an adverse determination may result in each party having responsibility for any amount of Income Taxes under this AgreementSection 9, each party shall be entitled to fully participate in that portion of the proceedings relating to the Income Taxes with respect to which it may incur liability hereunder. For purposes of this Section 9(d9.5(b), the term "participation" shall include (i) participation in conferences, meetings or proceedings with any tax authorityTax Authority, the subject matter of which includes an item for which such party may have liability hereunder, (ii) participation in appearances before any court or tribunal, the subject matter of which includes an item for which a party may have liability hereunder hereunder, and (iii) with respect to the matters described in the preceding clauses (i) and (ii), participation in the submission and determination of the content of the documentation, protests, memoranda memorandum of fact and law, briefs briefs, and the conduct of oral arguments and presentations.