Tax Grouping. (a) The Company has not, nor at any time in the past has had, its tax affairs dealt with on a consolidated basis nor have any of them entered into any tax sharing arrangement (including without limitation any arrangement under which tax losses or tax reliefs are surrendered or claimed or agreed to be surrendered or claimed) in respect of its profits, gains or losses, except as set out in the Disclosure Letter which gives full details of any such arrangement that the Company has entered into. Such details include a list with registered names and particulars of any companies or entities which at any time have participated or are currently participating in such arrangement as well as full details explaining the scope of the arrangement.
(b) Except as provided in the Accounts, the Company is not, or will not be, under any obligation to make or have any entitlement to receive any payment in respect of any period ending on or before the Accounts Date under any arrangements referred to in sub-paragraph 4.6(a) above.
Tax Grouping. Except as provided in its Accounts, no member of the Sale Group is, nor will it be, under any obligation to make any payment to anyone (including but not limited to members of the Retained Group but excluding any member of the Sale Group) under any Tax grouping, Tax sharing, fiscal consolidation or similar arrangements.
Tax Grouping. Except as provided in its Accounts, no member of the NADL Group is, nor will it be, under any obligation to make any payment to anyone (including but not limited to members of the Seadrill Group but excluding any member of the NADL Group) under any Tax grouping, Tax sharing, fiscal consolidation or similar arrangements.
Tax Grouping. (a) No Group Company has, nor at any time since its Incorporation Date has had, its tax affairs dealt with on a consolidated basis or formed a fiscal unity nor have any of them entered into any tax allocation or sharing arrangement (including any arrangement under which tax losses or tax reliefs are transferred, surrendered or claimed or agreed to be transferred, surrendered or claimed) in respect of its profits, gains or losses other than a group consisting solely of the Group Companies.
(b) No Group Company has acquired any asset from any other company which was, at the time of the acquisition, a member of the same group of companies as the relevant Group Company.
(c) The Company has not made or received, and is not obliged to make or entitled to receive, any payment in respect of group relief relating to any period ending on or before Completion.
Tax Grouping. (i) be, or apply to the Commissioner of Inland Revenue to be, a member of a group of companies pursuant to and for the purposes of the Goods and Services Tax Xxx 0000 except where all other members of that group of companies are Obligors;
(ii) be, or apply to the Commissioner of Inland Revenue to be, a member of a group of companies for any tax year for income tax purposes pursuant to and for the purposes of the Income Tax Xxx 0000 except where all other members of that group of companies are Obligors; or
(iii) transfer or acquire any tax losses except where:
(1) such transfer or acquisition is to or from any other Obligor;
(2) the tax losses are made available to the Obligor pursuant to an election made under section IC 5(2)(a) of the Income Tax Xxx 0000; or
Tax Grouping. (a) The Company has not, nor at any time in the last ten years has had, its tax affairs dealt with on a consolidated basis nor have any of them entered into any tax sharing arrangement (including without limitation any arrangement under which tax losses or tax reliefs are surrendered or claimed or agreed to be surrendered or claimed) in respect of its profits, gains or losses.
Tax Grouping. No member of the Group has its Tax affairs dealt with on a consolidated basis nor has any member of the Group entered into any Tax sharing arrangement (including without limitation any arrangement under which Tax losses or Tax reliefs are surrendered or claimed or agreed to be surrendered or claimed) in respect of the profits, gains or losses of that member of the Group with any company not being another member of the Group.
Tax Grouping. No Target Group Company has, nor at any time since the Relevant Date has had, its Tax affairs dealt with on a consolidated basis or formed a fiscal unity.
Tax Grouping. (1) No Company has at any time within the last six years had its tax affairs dealt with on a consolidated basis nor has any Company entered into any tax sharing arrangement with any other company (including, without limitation, any arrangement under which tax losses or tax reliefs are surrendered or claimed or agreed to be surrendered or claimed).
(2) The Disclosure Letter gives details of every written arrangement referred to in paragraph (1) above that a Company has entered into.
(3) Except as provided in the Financial Information no Company is nor will it be under any obligation to make or have any entitlement to receive any payment in respect of any period ending on or before the Accounts Date under the arrangements referred to in paragraph (1) above.
