Tax Relief. In the event the Client requests that the Custodian provide tax relief services and the Custodian agrees to provide such services, the Custodian shall apply for appropriate tax relief (either by way of reduced tax rates at the time of an income payment or retrospective tax reclaims in certain markets as agreed from time to time); provided the Client provides to the Custodian such documentation and information as to it or its underlying beneficial owner clients as is necessary to secure such tax relief. However, in no event shall the Custodian be responsible, or liable, for any Taxes resulting from the inability to secure tax relief, or for the failure of any Client or beneficial owner to obtain the benefit of credits, on the basis of foreign taxes withheld, against any income tax liability.
Tax Relief. The Custodian will provide tax relief services in relation to designated markets as may be specified from time to time in the Client Publications. Subject to the preceding sentence and compliance by the Fund with its obligations under Section 7.1, the Custodian will apply for a reduction of withholding tax and refund of any tax paid or tax credits which apply in each applicable market in respect of income payments on securities for the benefit of the Fund. Unless otherwise informed by the Fund, the Custodian shall be entitled to apply categorical treatment of the Fund according to its nationality, particulars of its organization and other relevant details supplied by the Fund.
Tax Relief. The Custodian will apply for a reduction of withholding tax and refund of any tax paid or tax credits in respect of income payments on Securities based on the Client’s entitlement under relevant tax treaties or laws which apply in each market that supports a standard tax reclaim process, in all cases as may be set out from time to time in the Client Publications. The Custodian does not facilitate tax reclaims for tax transparent or pass-through (i.e., multiple-beneficiary) entities such as partnerships, LLCs, common trusts or any other types of entities that are generally ineligible for tax treaty or domestic law tax entitlements, even where the partners or beneficial holders of such entities may be eligible.
Tax Relief. The Custodian will provide tax relief services in relation to designated markets as may be specified from time to time in the Client Publications. Subject to the preceding sentence and compliance by the Fund with its obligations under Section 7.1, the Custodian will file claims for exemptions, reductions of withholding tax, and refunds of any tax paid or tax credits which apply in each applicable market (domestic or foreign) in respect of income payments on securities for the benefit of the Fund. The Custodian shall provide information on reduction at source and tax reclaim processing in its Tax Entitlement Service Overview made available to the Fund on the Custodian’s customer portal, “xx.xxxxxxxxxxx.xxx.” The Custodian shall maintain tax entitlement accruals for possible tax benefits available in markets of investment and monitor tax entitlements and tax reclaim accruals based on existing situations in markets of investment with respect to the Fund’s entitlements. The Custodian shall facilitate communications to the Fund’s local tax consultants and Eligible Foreign Custodians with respect to reporting, payment and filing requirements regarding capital gains processing. Unless otherwise informed by the Fund, the Custodian shall be entitled to apply categorical treatment of the Fund according to its nationality, particulars of its organization and other relevant details supplied by the Fund.
Tax Relief. The Custodian will provide tax relief services in relation to designated markets as may be specified from time to time in the Client Publications. Subject to the preceding sentence and compliance by the Fund with its obligations under Section 7.1, the Custodian will apply for a reduction of withholding tax and refund of any tax paid or tax credits which apply in each applicable market in respect of income payments on securities for the benefit of the Fund. The Custodian shall provide information on reduction at source and tax reclaim processing in its Tax Entitlement Service Overview made available to the Fund on the Custodian’s customer portal,
Tax Relief. The Custodian will provide tax relief services in relation to designated markets as may be specified from time to time in the Client Publications. Custodian shall reasonably monitor the availability of such tax refunds in each market and make available to the Funds the anticipated recovery amounts. Subject to the preceding sentence and compliance by a Fund with its obligations under Section 7.1, the Custodian will apply for a reduction of withholding tax and refund of any tax paid or tax credits which apply in each applicable market in respect of income payments on securities for the benefit of a Fund. Unless otherwise informed by a Fund, the Custodian shall be entitled to apply categorical treatment of a Fund according to its nationality, particulars of its organization and other relevant details supplied by a Fund.
Tax Relief. In the event the Trust requests that Citi provide tax relief services and Citi agrees to provide such services, Citi will apply for appropriate tax relief (either by way of reduced tax rates at the time of an income payment or retrospective tax reclaims in certain markets as agreed from time to time); provided the Trust provides to Citi such documentation and information as to it or its underlying beneficial owner Trusts as is necessary to secure such tax relief. However, in no event will Citi be responsible, or liable, for any Taxes resulting from the inability to secure tax relief, or for the failure of any Trust or beneficial owner to obtain the benefit of credits, on the basis of foreign taxes withheld, against any income tax liability.
Tax Relief. The Custodian shall use all commercially reasonable efforts to apply for appropriate tax relief (either by way of reduced tax rates at the time of an income payment or retrospective tax reclaims in certain markets as agreed from time to time); provided the Client provides to the Custodian such documentation and information as to it or its underlying beneficial owner clients as is necessary to secure such tax relief. However, in no event shall the Custodian be responsible, or liable, for any Taxes resulting from its non-negligent inability to secure tax relief, or for the failure of any Client or beneficial owner to obtain the benefit of credits, on the basis of foreign taxes withheld, against any income tax liability.
Tax Relief. (a) If the Seller elects in its sole discretion, to the extent permissible under applicable Law, the Seller shall be permitted to procure the surrender of Group Relief from itself or the Parent or their Retained Affiliates to the Company or a Transferred Subsidiary in order to prevent or extinguish a liability for Taxes arising for which it would be liable under Article VIII, provided that no payment shall be due from the Company or any Transferred Subsidiary in respect of such claim. The Acquiror shall, and shall cause the Company and each Transferred Subsidiary to, take all steps reasonably requested to effect any such claim.
(b) Subject to paragraph (i) below, the Acquiror shall, at the written request of the Seller, procure that the Company and any Transferred Subsidiaries shall, to the extent legally permissible, claim Group Relief from the company or companies stated in the aforementioned written request for a consideration calculated in accordance with paragraph (ii) below.
(i) The Acquiror shall have no obligations under this Section 8.06(b) to pay consideration if and to the extent it would otherwise be calculated by reference to Tax in respect of which the Seller is liable under Article VIII.
(ii) The consideration to be provided in accordance with Section 8.06(b) above shall be an amount equal to:
(A) in the case of a Group Relief claim in relation to an accounting period of the Company or the relevant Transferred Subsidiary other than the Straddle Period, an amount equal to any amount of Tax for which the Company or that Transferred Subsidiary would otherwise be liable in respect of the relevant accounting period and which is reduced or eliminated (whether by way of refund, credit, offset or discharge) as a consequence of the Group Relief claim.
(B) in the case of a Group Relief claim in relation to the Straddle Period, an amount equal to any amount of Tax duly apportioned in accordance with Section 8.06(b)(iii)(D) to the part of the Straddle Period ending on the Closing Date for which the Company or the relevant Transferred Subsidiary would otherwise be liable in respect of that accounting period and which is reduced or eliminated (whether by way of refund, credit, offset or discharge) as a consequence of the Group Relief claim.
(iii) The Acquiror will procure that:
(A) the Company and all Transferred Subsidiaries will co-operate with the Seller in relation to any claim made under this Section 8.06(b) by promptly taking all such action as the ...
Tax Relief. In the event the Client requests that the Custodian provide tax relief services and the Custodian agrees to provide such services, the Custodian shall apply for appropriate tax relief (either by way of reduced tax rates at the time of an income payment or retrospective tax reclaims in certain markets as agreed from time to time); provided that the Client provides to the Custodian such documentation and information as is necessary to secure such tax relief. In no event shall the Custodian be responsible for the difference between the statutory rate of withholding and the treaty rate of withholding if the Custodian is unable to secure tax relief.
