OVERSEAS ELEMENTS. 4.1 The Company has never been resident or had a branch, agency, place of business, any permanent establishment (within the meaning of section 1141 CTA 2010) or subsidiary incorporated outside the United Kingdom and has never carried out any trading activities outside the United Kingdom for the purposes of any Tax Legislation.
OVERSEAS ELEMENTS. 12.1 The Target has never been resident or treated for the purposes of any double Tax arrangements having effect by virtue of section 788 Taxes Act (relief by arrangement with other countries) as being resident for Tax purposes in a territory outside the United Kingdom nor does it carry on any trading activities outside the United Kingdom.
OVERSEAS ELEMENTS. 4.1 The Group has never been resident or had a branch, agency, place of business, any permanent establishment (within the meaning of section 1141 CTA 2010) or subsidiary incorporated outside the United Kingdom and has never carried out any trading activities outside the United Kingdom for the purposes of any Tax Legislation.
OVERSEAS ELEMENTS. 16.1 The Company has not, without the prior consent of HM Treasury, done or been party to the doing of any act which amounted to or resulted in or formed part of a series of acts which together resulted in or amounted to a transaction which was unlawful under section 765 ICTA.
OVERSEAS ELEMENTS. (a) The Company does not carry on any trading activities outside the United Kingdom.
OVERSEAS ELEMENTS. 35.7.1. The Companies have made all appropriate claims for relief under Double Taxation Relief Conventions, orders or other agreements current at the date of this Agreement and have obtained full double tax relief for all income from outside the United Kingdom.
OVERSEAS ELEMENTS. The Group Companies only have trade, business or other activities in the PRC and do not have any overseas operating subsidiary or associated or related company (as such terms are used in relation to Tax in any foreign country) other than in the PRC.
OVERSEAS ELEMENTS. 9.1 The Company has not entered into any unlawful transaction under section 765 of the ICTA before 1 July 2009 nor reportable event within Schedule 17 to the FA 2009.
OVERSEAS ELEMENTS. The Company has never been resident or had a branch, agency, place of business, any permanent establishment (within the meaning of the OECD Model Double Taxation Agreement) or subsidiary incorporated outside the United Kingdom and has never carried out any trading activities outside the United Kingdom for the purposes of any Tax Legislation. 4.
OVERSEAS ELEMENTS. 28.1 The Company is not holding, nor has it held in the past seven years, any interest in any company the profits of which are, or have been, liable to the CFC charge within Chapter 2 of Part 9A of the TIOPA or Chapter IV of Part XVII of the ICTA. The Company does not have any material interest in an offshore fund as defined in Part 1 of Schedule 22 to the Finance Axx 0000.
