Tax avoidance. (i) In general. If, as of the agreement date, a significant difference between the marginal tax rates of the lessor and lessee can rea- sonably be expected at some time dur- ing the lease term, the agreement will be closely scrutinized and clear and convincing evidence will be required to establish that tax avoidance is not a principal purpose for providing increas- ing or decreasing rent. The term ‘‘marginal tax rate’’ means the per- centage determined by dividing one dollar into the amount of the increase or decrease in the Federal income tax liability of the taxpayer that would re- xxxx from an additional dollar of rental income or deduction.
Tax avoidance. (a) No member of the Group has entered into or been engaged in or been a party to any transaction which is artificial or fictitious or any transaction or series of transactions or scheme or arrangement of which the main or dominant purpose (or one of the main or dominant purposes) was the avoidance or deferral of or reduction in a liability for Tax.
(b) No member of the Group has been involved in any transaction, or series of transactions, or part of transactions that may for any Tax purposes be disregarded, recharacterised or reconstructed by reason of any motive to avoid, reduce or delay a possible liability to Tax.
(c) All agreements and arrangements entered into by the Issuer and/or between members of the Group in relation to the Business have been entered into and effected on an arm’s length basis and in accordance with the transfer pricing principles, laws and documentation requirements applied by Tax Authorities in all relevant jurisdictions.
Tax avoidance. The Company has not been involved in any scheme, arrangement, transaction or series of transactions in which the main purpose, or one of the main purposes was or might be held to have been: (i) the avoidance, deferral or reduction of Tax; (ii) the production of a loss for Tax purposes with no corresponding commercial loss, or (iii) to contain one or more steps which have no commercial purpose other than avoiding, deferring or saving Tax or obtaining a Tax advantage.
Tax avoidance. No Group Company has been a party to, or been involved in, any transaction, scheme or arrangement of which the main purpose (or one of the main purposes) or effect is the avoidance of a liability to Taxation or which could be re-characterised or treated as unenforceable for Taxation purposes.
Tax avoidance. 9.1 No Group Company has been a party to nor otherwise involved in any transaction, scheme or arrangement the main purpose or object or one of the main purposes or objects of which was to avoid, reduce or defer a liability to Tax.
9.2 No Group Company has been involved in any transaction or series of transactions which, or any part of which, may for any Tax purpose need to be specifically disclosed to a Tax Authority other than as part of routine periodic compliance or which is at risk of being disregarded, recharacterised or reconstructed by reason of any motive to avoid, reduce or delay a possible liability to Tax.
9.3 So far as the Seller is aware, no Group Company has participated in any "reportable transaction" within the meaning of Sections 6011, 6662A and 6707A of the Code.
Tax avoidance. So far as the Seller is aware, no Group Company has been a party to any transaction, scheme or arrangement with the main purpose of avoiding or evading Tax.
Tax avoidance. Neither the Company nor its Subsidiaries have entered into, or been a party to or otherwise involved in any transactions or dealings which contravenes, or may contravene, any anti-avoidance provisions of any Tax law including, but not limited to Part IVA of the 1936 Act. Without limiting the preceding paragraph, neither the Company or its Subsidiaries have been involved in any transaction or series of transactions which, or any part of which, may for any Tax purposes be disregarded or reconstructed by reason of any motive to avoid, reduce or delay a possible liability to Tax.
Tax avoidance. The Company has not been a party to, or been involved in, any schemes or arrangements designed wholly or partly for the purposes of avoiding or deferring any Tax liability, or in relation to which any disclosure has been, or will be, required by law to be made to any Tax Authority.
Tax avoidance. 6.1 The Company has never entered into a transaction to which the provisions of any Tax avoidance laws are applicable other than transactions in respect of which appropriate clearances have been obtained on the basis of full and accurate disclosure to the appropriate Tax Authority of all material facts and considerations material to be known to the appropriate Tax Authority.
6.2 Any transaction for which consent or clearance (of the nature referred to in paragraph 5.1 above) has previously been obtained has been carried into effect (if at all) only in accordance with the terms of the application requesting such consent or clearance.
Tax avoidance. The Company has not entered into any transaction or series of transactions, scheme or arrangement of which the main purpose, or one of the main purposes, was the avoidance or reduction of a Taxation liability or for which there was no commercial purpose.
