Tax Treaty. Each Lender that is organized under the laws of a country other than the United States of America agrees (a) on or before the date the first Advance is made, to complete and deliver to Borrowers Internal Revenue Service Form 4224, and (b) to complete and deliver to Borrowers from time to time, provided such Lender is eligible to do so, any successor or additional forms required in order to secure an exemption from, or reduction in the rate of, income tax withholding imposed by the United States of America. Each Lender shall amend or supplement any such form as required and permitted by applicable law to insure that it is in full force and effect, accurate and complete at all times.
Tax Treaty. Holdings is a resident of the Netherlands within the meaning of Article 4 of the Convention between Venezuela and the Netherlands for the Avoidance of Double Taxation and Fiscal Evasion on Income and its Protocol (the "Convention"). Holdings does not have a permanent establishment in Venezuela within the meaning of Section 5 of the Convention. Holdings has received a residency certificate from the Netherlands sufficient under the Ley de Impuesto Sobre la Renta of Venezuela for purposes of receiving tax benefits pursuant to the Convention.
Tax Treaty. If so required by law IMagic may deduct from the amount due to be paid pursuant to this Agreement a withholding tax of not more than 5 per cent pursuant to the US-France Income Tax Convention, provided IMagic provides a copy of any payment stub and official tax receipt demonstrating that such withholding tax has been paid to the U.S. and State taxation authorities and provided further that if Ubi Soft is unable to use the tax credit to its fullest extent, then IMagic shall immediately pay the balance required to gross up the relevant payment so that the net amount received by Ubi Soft is not less than the gross amount due.
Tax Treaty. 14 Section 3.12 Brokers......................................................14
Tax Treaty. Itochu and Converse acknowledge that this Agreement is a ----------- sale for the purposes of Articles 14 and 16 of the United States/Japan Tax treaty.
Tax Treaty. Each Lender that is organized under the laws of a country other than the United States of America agrees:
Tax Treaty. Each Lender organized under the laws of a jurisdiction outside the United States (a "Foreign Lender") as to which payments to be made under this Credit Agreement or under the Notes are exempt from United States withholding tax under an applicable statute or tax treaty shall provide to the Borrower and the Agent a properly completed and executed IRS Form 4224 or Form 1001 or other applicable form, certificate or document prescribed by the IRS or the United States certifying as to such Foreign Lender's entitlement to such exemption (a "Certificate of Exemption"). Any foreign Person that seeks to become a Lender under this Agreement shall provide a Certificate of Exemption to the Borrower and the Agent prior to becoming a Lender hereunder. No foreign Person may become a Lender hereunder if such Person is unable to deliver a Certificate of Exemption.
Tax Treaty. 27 Section 8. Security........................................................ 28
