Tax Treaty Relief Sample Clauses

Tax Treaty Relief. 6.6.1 The Lender shall once in each calendar year, prior to the first Interest Payment Date in that calendar year, at the expense of the Borrower, use commercially reasonable efforts to obtain and deliver, to the Borrower no later than 10 Business Days prior to such Interest Payment Date, a tax residency certificate issued by the competent authorities of Ireland confirming that the Lender is resident for tax purposes in Ireland. At the cost of the Borrower, the residency certificate shall be apostilled at the Irish Department of Foreign Affairs. Provided that the tax residency certificate application has been filed in due time, the Lender shall not be responsible for any failure to provide, or any delays in providing, such tax residency certificate as a result of any action or inaction of any authority of Ireland, but shall notify the Borrower as soon as practicable about any such failure or delay with an indication of the actions taken by the Lender to obtain such tax residency certificate. 6.6.2 If Russian legislation regulating the procedures for obtaining an exemption from Russian withholding tax on income changes, the Lender shall (subject to being informed of any such changes by the Borrower) use its reasonable and timely efforts to assist the Borrower to obtain relief from such tax pursuant to the double taxation treaty between the Russian Federation and Ireland and the procedures referred to in Clause 6.6.1 will be deemed changed accordingly.
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Tax Treaty Relief. 6.6.1 The Lender shall once in each calendar year, no later than 10 Business Days prior to the first date on which any payment by NN is due hereunder in that calendar year, deliver to NN, at the expense of NN (provided that the incurred expenses are reasonable and documented), a notarised tax residency certificate issued or certified by (as applicable) the competent authorities of Ireland confirming that the Lender is resident in Ireland for the purposes of the agreement between Ireland and the Russian Federation for the avoidance of double taxation with respect to income in that calendar 6.6.2 If Russian legislation regulating the procedures for obtaining an exemption from Russian withholding tax on income changes, the Lender shall use its reasonable and timely efforts to assist NN to obtain relief from such tax pursuant to the double taxation treaty between the Russian Federation and Ireland. In all other cases, the Lender shall, subject to being fully indemnified by NN for all documented costs it incurs in so doing, co-operate with NN in completing any procedural formalities necessary for NN to obtain authorisation to make any payment without any deduction or withholding on account of any Taxes. 6.6.3 Notwithstanding sub-clause 6.4, if NN makes a withholding or deduction for or on account of Taxes from a payment under or in respect of this Agreement, NN may apply on behalf of the Lender to the relevant taxing authority of the Russian Federation (the “Russian Taxing Authority”) for a payment to be made by such authority to the Lender with respect to such Tax. If, whether following a claim made on its behalf by NN or otherwise, the Lender receives such a payment (“Russian Tax Payment”) from the Russian Taxing Authority with respect to such Taxes, it will as soon as reasonably possible notify NN that it has received that payment (and the amount of such payment); whereupon, provided that NN has notified the Lender in writing of the details of an account (the “Borrower Account”) to which a payment or transfer should be made, and that the Lender is able to make a payment or transfer under applicable laws and regulations, the Lender will, as soon as reasonably practicable, pay or transfer an amount equal to the Russian Tax Payment to the Borrower Account. 6.6.4 The Xxxxxx agrees promptly, upon becoming aware thereof, to notify NN if it ceases to be resident in Ireland for tax purposes. 6.6.5 Subject to sub-clauses 6.5 and 8.2, the Lender agrees that it shall m...
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Tax Treaty Relief. The Lender, at the cost of the Borrower, shall make reasonable and timely efforts to assist the Borrower to obtain relief from withholding of Russian income tax pursuant to the double taxation treaty between Russia and Ireland, including its obligations under Clause 6.9 (Delivery of forms).
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Tax Treaty Relief. 7.6.1 The Lender shall once in each calendar year, prior to the first Interest Payment Date in that calendar year, at the expense of the Borrower, use its best efforts to obtain and deliver, to the Borrower no later than 10 Business Days prior to such Interest Payment Date, a tax residency certificate issued by the competent authorities of the Netherlands (or another relevant Qualifying Jurisdiction) confirming that the Lender is resident for tax purposes in the Netherlands (or such other relevant Qualifying Jurisdiction) and that it has fulfilled any conditions which must be fulfilled under the applicable Treaty for residents of the Netherlands (or another relevant Qualifying Jurisdiction) to obtain either: (a) full exemption from Tax in the Republic of Armenia on interest payable to the Lender in respect of payments due under the Facility; or (b) partial exemption from Tax in the Republic of Armenia on such interest, reducing the rate of such Tax to a rate which is no higher than the minimum rate prescribed by a Treaty. 7.6.2 The Lender shall use its reasonable and timely efforts to assist the Borrower, at the expense of the Borrower, in obtaining relief from withholding of Armenian income tax pursuant to the applicable Treaty, including completing any and all procedural formalities necessary (including but not limited to any requirements of such applicable Treaty, in each case subject to being informed of any such formalities by the Borrower).
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Tax Treaty Relief. ‌ (a) The Lender shall at the cost and expense of the Borrower use all reasonable endeavours to provide the Borrower with a certificate issued by the competent taxing authorities in the Qualifying Jurisdiction confirming that the Lender is a tax resident of a Qualifying Jurisdiction for the purpose of the Treaty no later than 10 Business Days before the first Interest Payment Date (and thereafter as soon as possible at the beginning of each calendar year but not later than 10 Business Days prior to the first Interest Payment Date in that year) and such other information or forms as may be reasonably requested by the Borrower to enable it to apply to obtain relief from deduction or withholding of Russian taxes after the date of this Agreement or, as the case may be, to apply to obtain a tax refund if a relief from deduction or withholding of Russian taxes has not been obtained, provided that the Lender shall not be liable for any failure to provide, or any delays in providing, such residency certificate as a result of any action or inaction of the competent tax authorities in the Qualifying Jurisdiction, but shall notify the Borrower without delay about any such failure or delay with a written description of the actions taken by the Lender to obtain such tax residency certificate. Such a certificate shall be appropriately apostilled and a certified translation shall be supplied at the expense of the Borrower. (b) The Borrower and the Lender acknowledge that the Russian legislation regulating the procedure for obtaining access to Treaty benefits, as well as the practical approach and technical interpretations of the Russian tax authorities, may be subject to change. The Borrower and the Lender further acknowledge that any such change may result in access to Treaty benefits, and in particular to obtaining the reduced rate of
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Related to Tax Treaty Relief

  • Income Tax Treatment Employee and the Company acknowledge that it is the intention of the Company to deduct all amounts paid under Section 2 hereof as ordinary and necessary business expenses for income tax purposes. Employee agrees and represents that he will treat all such amounts as required pursuant to all applicable tax laws and regulations, and should he fail to report such amounts as required, he will indemnify and hold the Company harmless from and against any and all taxes, penalties, interest, costs and expenses, including reasonable attorneys' and accounting fees and costs, which are incurred by Company directly or indirectly as a result thereof.

  • Tax Treatment If any interest in any Loan Document is transferred to any Transferee which is organized under the laws of any jurisdiction other than the United States or any State thereof, the transferor Lender shall cause such Transferee, concurrently with the effectiveness of such transfer, to comply with the provisions of Section 3.5(iv).

  • Tax Treatment of Indemnity Payments Seller and Buyer agree to treat any indemnity payment made pursuant to this Article X as an adjustment to the Purchase Price for Tax purposes.

  • No Tax Advice Neither Plaintiff, Class Counsel, Defendant nor Defense Counsel are providing any advice regarding taxes or taxability, nor shall anything in this Settlement be relied upon as such within the meaning of United States Treasury Department Circular 230 (31 CFR Part 10, as amended) or otherwise.

  • Intended Tax Treatment Notwithstanding anything to the contrary herein or in any other Transaction Document, all parties to this Agreement covenant and agree to treat each Loan under this Agreement as debt (and all Interest as interest) for all federal, state, local and franchise tax purposes and agree not to take any position on any tax return inconsistent with the foregoing.

  • Tax Advice You are encouraged to obtain your own tax advice regarding your compensation from the Company. You agree that the Company does not have a duty to design its compensation policies in a manner that minimizes your tax liabilities.

  • Federal Income Tax Treatment It is the intention of the Trust Depositor that the Trust be disregarded as a separate entity for federal income tax purposes pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii) as in effect for periods after January 1, 1997. The Equity Certificate constitutes the sole equity interest in the Trust and must at all times be held by either the Trust Depositor or its transferee as sole Owner. The Trust Depositor agrees not to take any action inconsistent with such intended federal income tax treatment. Because for federal income tax purposes the Trust will be disregarded as a separate entity, Trust items of income, gain, loss and deduction for any month as determined for federal income tax purposes shall be allocated entirely to the Owner; provided, that this sentence shall not limit or otherwise affect the provisions of the Transaction Documents pertaining to distributions of Trust Assets or proceeds thereof to Persons other than the Trust Depositor.

  • Payee Tax Representations Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • Agreed Tax Treatment Each Security issued hereunder shall provide that the Company and, by its acceptance of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a beneficial interest in, such Security agree that for United States Federal, state and local tax purposes it is intended that such Security constitutes indebtedness.

  • Special Tax Treatment Capital gains treatment and 10-year forward income averaging authorized by IRC Sec. 402 do not apply to IRA distributions.

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