Group arrangements. 8.5.1 The Company has never been a member of any group of companies for any Taxation purpose other than of the Group.
Group arrangements. 34.1 The Company is the beneficial owner of all the shares in each Subsidiary and no such shares are held such that any profit on the sale of those shares would be a trading receipt.
Group arrangements. 47.1 All the shares in each Subsidiary are beneficially owned by Group Members and no such shares are held such that any profit on the sale of those shares would be a trading receipt.
Group arrangements. 8.6.1 The Company has not since the Balance Sheet Date ceased to be a member of a group of companies for the purposes of sections 178 and 179 TCGA.
Group arrangements. 11.1 The Buyer shall procure that the Company which is a member of the group payment arrangement with the Seller or any member of the Seller’s Group made pursuant to section 36 FA 1998 (GPA) contributes to British United Provident Association Limited (Nominated Company), on whichever is the later of five Business Days after written demand is made therefor by the Seller to the Buyer or five Business Days before the due date for payment to HM Revenue & Customs of the underlying corporation tax liability, an amount equal to any, or any instalment of, corporation tax which is to be or has been discharged by the Nominated Company on behalf of the Company in question (the “Payment”), pursuant to the GPA (as certified by the Nominated Company), provided always that no such contribution shall be made to the extent that the Buyer would otherwise have been able to make a claim against the Seller under this Schedule (disregarding paragraphs 2, 3 and 4 of Schedule 5) in respect of such corporation tax or instalment of corporation tax or to the extent that such contribution was paid on or before Completion.
Group arrangements. No member of the Group has in the past six years received any payment in respect of a surrender of group relief or of surplus advance corporation Tax or of a Tax refund which could, in any circumstances, be due to be repaid to any company other than another member of the Group.
Group arrangements. 11.8 The Purchaser shall or shall procure that each Target Company which is a member of a Seller VAT group (of which British Nuclear Fuels PLC and British Nuclear Group Sellafield Limited, respectively, are the representative members) contributes to the relevant representative member such proportion of any value added tax for which the relevant representative member is accountable as is properly attributable to supplies, acquisitions and importations (supplies) made by each such Target Company whilst a member of that VAT group (less such amount of deductible input tax as is properly attributable to such supplies), such contribution to be made in cleared funds on the day which is the later of two Business Days after demand is made therefor, and two Business Days before the day on which the relevant representative member is required to account for such value added tax to HM Private and confidential Revenue & Customs. The Seller shall pay, or shall procure that there is paid, to the Company (on behalf of itself and each other relevant Target Company) an amount equivalent to such proportion of any repayment of value added tax received by the relevant representative member from HM Revenue & Customs or of any credit obtained by reference to an excess of deductible input tax over output tax that is properly attributable to supplies made to and by the Target Companies whilst members of a Seller VAT group, promptly after its receipt by, or offset against a liability of, the relevant representative member. The Purchaser shall provide such information as may be reasonably required to enable the relevant representative member to make the returns and provide the information required to be provided for VAT purposes.
Group arrangements. Parent shall procure that each Target Company and Company Subsidiary will cease to be a member of or party to any relevant grouping, fiscal unity, tax sharing arrangement, tax sharing agreement or consolidation for Tax purposes (for the purposes of direct and indirect Tax, including VAT) with any member of Parent Group, no later than Closing.
Group arrangements. 33.1 The first named member listed at paragraph (H) in that part of Attachment 2, Part B (Basic Information about the Subsidiaries) which relates to each member of the Group (apart from the Company) is the beneficial owner of all the shares in that member of the Group and no such shares are held such that any profit on the sale of those shares would be a trading receipt.
Group arrangements. 9.1 The Seller shall remove, or procure that the relevant member of the Seller’s Group shall remove, the DivestCo Group Companies from all group arrangements of the Seller’s Group for Tax purposes with effect from Completion.
