Common use of Tax Residence Clause in Contracts

Tax Residence. The Company is and has been at all times resident for all tax purposes (including any double tax treaty) only in the United Kingdom and is not, and has not been treated, as resident in any other jurisdiction for any tax purpose (including any double tax treaty), other than through the ownership of “qualified business units” that are treated as non-United Kingdom residents pursuant to Section 988(a)(3)(B)(ii) of the Code for purposes of determining the source of foreign currency gain or loss for U.S. federal income tax purposes.