Common use of Tax Credits; Deferred Intercompany Gains Clause in Contracts

Tax Credits; Deferred Intercompany Gains. For purpose of the calculations under this Agreement, any loss of Tax credits resulting from or attributable to the transfer of assets to Grant or any other member of the Grant Group in connection with the Spin-Off shall be ignored and all calculations shall be made as though all such tax credits were available for use by the Weatherford Group. In the event any deferred intercompany gain attributable to assets transferred to Grant or any other members of the Grant Group by other members of the Weatherford Group is recognized by the Weatherford Group by reason of the Spin-Off, such deferred intercompany gain, if any, shall be deemed to be gain of the Grant Group for its taxable year ending on the Spin-Off Date for purposes of all calculations under this Agreement.

Tax Credits; Deferred Intercompany Gains. For purpose of the calculations under this Agreement, any loss of Tax credits resulting from or attributable to the transfer of assets to Grant or any other member of the Grant Group in connection with the Spin-Off shall be ignored and all calculations shall be made as though all such tax credits were available for use by the Weatherford Group. In the event any deferred intercompany gain attributable to assets transferred to Grant or any other members of the Grant Group by other members of the Weatherford Group is recognized by the Weatherford Group by reason of the Spin-Off, such deferred intercompany gain, if any, shall be deemed to be a gain of the Grant Group for its taxable year ending on the Spin-Off Date for purposes of all calculations under this Agreement, including the calculation of Taxes owed by Grant to Weatherford pursuant to Paragraphs 3 and 5 hereof.