Tax Benefit Allocation. (a) The Shareholders hereby acknowledge that (i) before the Chilean Effective Time certain Bank Shares owned by the Companies had, either totally or partially, the exemption on capital gains set forth in Article 107 of the Chilean Income Tax Law entitling the holder of such Bank Shares to transfer them free of Chilean capital gains tax (the “Tax Entitlement”) and (ii) the Tax Entitlement remains in the Bank Shares held, directly or indirectly, by the Companies.
Appears in 4 contracts
Samples: Shareholders Agreement, Shareholders Agreement (Saieh Bendeck Alvaro), Transaction Agreement (Corpbanca/Fi)
Tax Benefit Allocation. (a) The Shareholders hereby acknowledge that (i) before the Chilean Effective Time certain Bank Shares owned by the Companies had, either totally or partially, the exemption on capital gains set forth in Article 107 of the Chilean Income Tax Law entitling the holder of such Bank Shares to transfer them free of Chilean capital gains tax (the “"Tax Entitlement”") and (ii) the Tax Entitlement remains in the Bank Shares held, directly or indirectly, by the Companies.
Appears in 1 contract
Samples: Shareholders Agreement (Itau Unibanco Holding S.A.)
