Group transactions. 7.1 The Company is not liable to make any payment for any Group Relief, a Tax Refund or advance corporation tax surrendered or to be surrendered to it and there are no amounts due or which may become due to the Company in respect of the surrender of any Group Relief, a Tax Refund or advance corporation tax. The Company is not liable to surrender any Group Relief, a Tax Refund or advance corporation tax under those provisions. There are no arrangements whereby the Company may become liable to repay any sums paid to it for the surrender of any Group Relief, a Tax Refund or advance corporation tax.
7.2 The Company has not within the last six years:
7.2.1 acquired any capital asset from any company which at the time of the acquisition was a member of the same group of companies as defined in section 170 TCGA;
7.2.2 joined in the making of any election pursuant to section 247 ICTA or paid any dividend without paying ("ACT") or made any payment without deduction of income tax in circumstances such that ACT ought to have been paid or income tax ought to have been deducted as mentioned in section 247(6) ICTA;
7.2.3 been the subject of or otherwise involved in any agreements as are referred to in section 240(11) or 410 ICTA;
7.2.4 acquired an asset as trading stock from a member of the same group where the asset did not form part of the trading stock of any trade carried on by the other member, as mentioned in section 173(1) TCGA, or disposed of an asset which formed part of the trading stock of any trade carried on by the Company to another member of the same group which acquired the asset otherwise than as trading stock of a trade carried on by the other member, as mentioned in section 173(2) TCGA; and
7.2.5 been, and there are no circumstances by virtue of which the Company could be, assessed or charged to corporation tax by virtue of the provisions of section 178(9), 179(11), 190 or 191 TCGA and is not entitled to recover or liable to have recovered from it any sums pursuant to any of those sections.
Group transactions. 6.1 The Company is not liable to make any payment (to any person other than another company falling within the definition of the Company) for any Group Relief or a Refund surrendered or to be surrendered to it and there are no amounts due or which may become due to the Company (from any person other than another company falling within the definition of the Company) in respect of the surrender of any Group Relief or a Refund. The Company is not liable to surrender (to any person other than another company falling within the definition of the Company) any Group Relief or a Refund under those provisions. There are no arrangements whereby the Company may become liable to repay (to any person other than another company falling within the definition of the Company) any sums paid to it for the surrender of any Group Relief or a Refund.
6.2 The Company has not at any time:
Group transactions. Within the last six years the Company has not been a member of a group of companies within the meaning of Section 170 TCGA (groups of companies).
Group transactions. 47.1 Since 28 June 1996 no Group Company has acquired any asset from any other company which was at the time of acquisition, and which has since the time of acquisition ceased to be a member of the same group of companies as that Group Company.
47.2 Since 28 June 1996 no Relevant Claim or Surrender has been claimed by any Group Company or taken into account in preparing the provision for Taxation in the Accounts (or in audited accounts for prior years) which could or might be effectively withdrawn, postponed, restricted or otherwise lost or not available and no Group Company is required to pay any sum in respect of any Relevant Claim or Surrender other than such sum as may be provided in the Accounts.
47.3 Since 28 June 1996 all Relevant Claims and Surrenders made by each Group Company were valid and have been or will be allowed by way of relief from Taxation.
Group transactions. 6.1 The Company has not at any time within the last 6 years acquired any asset from any company (other than a company falling within the definition of Company) which at the time of the acquisition was a member of the same group of companies as defined in section 170 TCGA.
6.2 The Company has not within the last six years made any election under section 171A or 179A TCGA or section 792 CTA 2009.
Group transactions. During the period between the Execution Date and Closing Date, all the transactions between the Company, the Group Companies and the Founders, and their respective Related Parties shall be conducted on an arm’s length basis in accordance with Applicable Laws for bona fide commercial considerations.
Group transactions. 19.1 Details of all claims for or surrenders of Group Relief pursuant to sections 402 and 413 ICTA, elections pursuant to sections 171A and 179A TCGA and elections pursuant to paragraph 66 of Schedule 29 FA 2002 to which any Group Member has been a party in the three years ending on Completion, including details of payments made or to be made and payments received or to be received are set out in the Disclosure Letter.
19.2 No Group Member has been a party to any such reconstruction as is described in section 343 ICTA in the six years prior to Completion;
19.3 So far as the Management Sellers are aware no Group Member owns an asset which, as a result of the sale of the Shares pursuant to this Agreement, will give rise to a charge under section 179 TCGA (de-grouping)
Group transactions. 6.1 The Company is not liable to make any payment (to any person other than another company falling within the definition of the Company) for any Group Relief or a Refund surrendered or to be surrendered to it and there are no amounts due or which may become due to the Company (from any person other than another company falling within the definition of the Company) in respect of the surrender of any Group Relief or a Refund. The Company is not liable to surrender (to any person other than another company falling within the definition of the Company) any Group Relief or a Refund under those provisions. There are no arrangements whereby the Company may become liable to repay (to any person other than another company falling within the definition of the Company) any sums paid to it for the surrender of any Group Relief or a Refund.
6.2 The Company has not at any time:
(a) acquired any asset from any company (other than another company falling within the definition of the Company) which at the time of the acquisition was a member of the same group of companies (for the purposes of any Taxation) nor has the Company entered into any election pursuant to section 171A or section 100X XXXX;
(b) acquired an asset as trading stock from a member of the same group where the asset did not form part of the trading stock of any trade carried on by the other member or disposed or an asset which formed part of the trading stock of any trade carried on by the Company to another member of the same group which acquired the asset otherwise than as trading stock of a trade carried on by the other member;
(c) ceased to be a member of a group of companies in such circumstances that a profit or gain was deemed to accrue to the Company and neither the execution of this Agreement, this Agreement becoming unconditional or Completion will result in any profit or gain being deemed to accrue to the Company for any Taxation purpose.
Group transactions. Details of all claims and surrenders and agreements and arrangements, relating to the claim or surrender by the Company of any Relief to or by any member of the Sellers' Group within the last three years are set out in the Disclosure Letter. The Company is not liable to make any payment for any Relief surrendered to it and there are no amounts due or which may become due to the Company in respect of the surrender of any Relief.
Group transactions. No Group Company has entered into any transactions, schemes or arrangements which give rise to a liability under Sections 000, 000, 000, 000, 000X, 000 XXX (xx any similar provisions of non-Irish Tax law); nor has any Group Company entered into any transactions, schemes or arrangements to which Sections 630 to 638 TCA (or any similar provisions of non-Irish Tax law) apply.
