RESIDENCE AND OFFSHORE INTERESTS. 5.1 The Company is and has at all times been resident for Tax purposes in its country of incorporation and is not and has not been treated as resident or as having a branch or permanent establishment in any other jurisdiction for any Tax purpose (including under any double taxation treaty or agreement). The Company has at no time incurred any liability to Tax under the laws of any jurisdiction other than the jurisdiction in which the Company is incorporated.
5.2 The Company is not liable for any Tax as the agent or Tax representative of any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
5.3 The Company does not and has at no time owned a beneficial interest in the capital of a company which is resident outside the United Kingdom.
RESIDENCE AND OFFSHORE INTERESTS. 5.1 The Company is and has at all times been resident in the United Kingdom for Tax purposes and is not and has not been treated as resident or as having a branch or permanent establishment in any other jurisdiction for any Taxation purpose (including under any double taxation treaty or agreement).
5.2 The Company is not liable for any Taxation as the agent or Tax representative of any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
5.3 The Company does not and has at no time owned a beneficial interest in the capital of a company which is resident outside the United Kingdom and which would be a close company if it were resident in the United Kingdom, in circumstances such that a chargeable gain accruing to that other company could be appointed to the Company under section 13 TCGA.
RESIDENCE AND OFFSHORE INTERESTS. 7.1 The Company is and has at all times been resident only in the United Kingdom for Tax purposes and is not and has not been treated as resident or as having a branch, agency, place of business or permanent establishment in any other jurisdiction for any Taxation purpose (including under any double taxation treaty or agreement) and is not liable to Tax (other than any tax withheld or deducted at source) in any other jurisdiction.
7.2 The Company is not liable for any Taxation as the agent or tax representative of any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
7.3 The Company does not and has at no time owned a beneficial interest in the capital of a company which is resident outside the United Kingdom and which would be a close company if it were resident in the United Kingdom, in circumstances such that a chargeable gain accruing to that other company could be appointed to the Company under section 13 TCGA.
RESIDENCE AND OFFSHORE INTERESTS. 13.1 The Target is and has at any time at all times been resident in the United Kingdom for Tax purposes and is not and has not at any time been treated as resident or as having a branch or permanent establishment in any other jurisdiction for any Taxation purpose (including under any double taxation treaty or agreement).
13.2 The Target is not liable for any Taxation as the agent or Tax representative or any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
13.3 The Target does not have, and has never had, an interest in a CFC as defined for the purposes of Part 9A of TIOPA or any interest in an offshore fund as defined in section 355 TIOPA.
RESIDENCE AND OFFSHORE INTERESTS. The Company is and has at all times been resident in the United Kingdom for the purposes of all Taxation Statutes and has not at any time been resident outside the United Kingdom for the purposes of any Taxation Statute or any double taxation arrangements and does not carry on any trade outside the United Kingdom.
RESIDENCE AND OFFSHORE INTERESTS. 8.1 The Company is and has at any time at all times been resident in the United Kingdom for Tax purposes and is not and has not at any time been treated as resident or as having a branch or permanent establishment in any other jurisdiction for any Taxation purpose (including under any double taxation treaty or agreement).
8.2 The Company is not liable for any Taxation as the agent or Tax representative of any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
RESIDENCE AND OFFSHORE INTERESTS. 7.1 The Company is and has at all times been resident in the county of its incorporation for Tax purposes and is not and has not been treated as resident or as having a branch or permanent establishment in any other jurisdiction for any Taxation purpose (including under any double taxation treaty or agreement).
7.2 The Company is not liable for any Taxation as the agent or Tax representative of any other person or business and does not constitute a permanent establishment of any other person, business or enterprise for any Taxation purposes.
7.3 The Company does not and has at no time owned a beneficial interest in the capital of a company which is resident outside the United Kingdom and which would be a close company if it were resident in the United Kingdom, in circumstances such that a chargeable gain accruing to that other company could be appointed to the Company under section 13 TCGA.
7.4 The Company has not received any asset by way of gift as mentioned in section 282 TCGA.
8.1 The Company is duly registered for the purposes of VATA. Such registration is not subject to any conditions imposed by or agreed with the Commissioners of HM Revenue and Customs. Within the last 3 years, the Company has complied in all material respects with VATA and all orders, provisions, directions or other conditions made or imposed thereunder or under any other law relating to VAT.
8.2 The Company is not and has never been a member of a group for the purpose of section 43 VATA.
8.3 The Company has not registered, and is not required to register, for VAT purposes (or for the purposes of any similar tax on added value or turnover) in any country other than the United Kingdom.
RESIDENCE AND OFFSHORE INTERESTS. 15.1 The Company is and has at all times been resident in the United Kingdom for the purposes of all Taxation Statutes and has not at any time been resident outside the United Kingdom for the purposes of any Taxation Statute or any double taxation arrangements.
15.2 The Company is not, and has never been, a dual-resident investing company within the meaning of Section 404 of the Taxes Act.
15.3 The Company has not at any time entered into any transaction falling within Section 765 of the Taxes Act or failed to comply with the requirements of Section 765A of the Taxes Act.
15.4 The Company has not at any time been subject to Taxation in any jurisdiction outside the United Kingdom or had a branch outside the United Kingdom or any permanent establishment (as that expression is defined in Section 148 of the Finance Act 2003) outside the United Kingdom.
15.5 No assessment in respect of a chargeable gain on the disposal of any asset of the Company situated outside the United Kingdom or of overseas income which is temporarily or permanently incapable of remittance to the United Kingdom has been postponed under the provisions of Section 279 of the TCGA (foreign assets: delayed remittances) or Section 584 of the Taxes Act (relief for unremittable overseas income — corporation tax).
15.6 The Company does not own and has not at any time owned a material interest in an offshore fund which is or has at any material time been a non-qualifying offshore fund within the meaning of Section 760 of the Taxes Act.
15.7 The Company does not own and has not at any time owned any interest in a controlled foreign company within the meaning of Chapter IV of Part XVII of the Taxes Act.
15.8 The Company is not assessable and has not at any time been assessed to tax under Section 126 of the Finance Xxx 0000.
RESIDENCE AND OFFSHORE INTERESTS. 31.1 The Company is and has at all times been resident in the United Kingdom for the purposes of all Taxation Statutes and has not at any time been resident outside the United Kingdom for the purposes of any Taxation Statute or any double taxation arrangements.
31.2 The Company is not, and has never been, a dual-resident investing company within the meaning of section 404 ICTA.
31.3 The Company has not at any time been subject to Taxation in any jurisdiction outside the United Kingdom or had a branch outside the United Kingdom or any permanent establishment (as that expression is defined in the respective double taxation relief orders current at the date of this Agreement) outside the United Kingdom.
31.4 The Company does not own and has not at any time owned any interest in a controlled foreign company within the meaning of sections 747 and 752 ICTA.
31.5 The Company does not and has at no time held shares in a company which is not resident in the United Kingdom and which would be a close company if it were resident in the United Kingdom, in circumstances such that a chargeable gain accruing to that other company could be apportioned to the Company under section 13 TCGA.
RESIDENCE AND OFFSHORE INTERESTS. (i) The Company is and has at all times been resident in the country in which it is incorporated for the purposes of all Taxation legislation and has not at any time been resident outside the country in which it has been incorporated for the purposes of any Taxation legislation or any double taxation arrangements.
(ii) The Company has not at any time been subject to Taxation in any jurisdiction outside the country in which it has been incorporated or had a branch outside that country or any permanent establishment (as that expression is defined in the respective double taxation relief orders current at the date of this Agreement) outside the country in which it is incorporated.
(iii) The Company does not own and has not at any time owned any interest in a controlled foreign company whose activities could give rise to a liability to Taxation for the Company in the country in which the Company has been incorporated.
