Taxation of Lenders. The foreign Lenders shall not be subject to taxation or withholding tax in Bangladesh in accordance with the applicable Statutory Regulatory Order (SRO) in effect as on Bid Date in respect of their income from interest arising from loans extended to the Company under the Financing Documents during the term of the Power Purchase Agreement subject, however, to the fulfillment of all applicable conditions specified in the relevant bilateral tax treaty applicable to each Lender’s country in conjunction with the Income Tax Ordinance, 1984 (Ord. No. XXXVI of 1984), amended at the time the related Financing Documents become effective.
Taxation of Lenders. The foreign Lenders shall not be subject to taxation or withholding tax in Bangladesh in respect of their income from interest and fees arising from loans extended to the Company under the Financing Documents during the term of the Power Purchase Agreement subject, however, to the fulfillment of all applicable conditions specified in the relevant bilateral tax treaty applicable to each Lender’s country in conjunction with the Income Tax Ordinance, 1984 (Ord. No. XXXVI of 1984), amended at the time the related Financing Documents become effective.
Taxation of Lenders. Notwithstanding any provision of this Agreement to the contrary, each Lender shall be either (a) a United States person under Section 7701(a)(30) of the Code for United States federal income purposes and shall deliver to the Borrower a properly completed and executed Internal Revenue Service Form W-9 (or any subsequent versions thereof or successors thereto), or (b) entitled to an exemption from withholding tax under the laws of the United States of America, or any treaty with the United States of America, or any treaty to which the United States of America is a party, with respect to payments under any Loan Documents and shall deliver to the Borrower, at the time or times prescribed by applicable law or reasonably requested by the Borrower, such properly completed and executed documentation prescribed by applicable law as will permit such payments to be made without withholding.
Taxation of Lenders. During the term of this Agreement, each non-resident Lender shall be subject to Liberian Taxes with respect to its Liberian source income, unless such Lender (a) is exempted from Liberia tax pursuant to the terms of a bilateral tax treaty between the GOL and the place of domicile of such Lender and (b) has fulfilled all applicable conditions specified in such bilateral tax treaty in conjunction with the Liberian Income Tax Ordinance, as amended at the time the related Financing Documents become effective, in which event such Lender shall not be subject to taxation or withholding of tax in Liberia regarding their income from interest, mark-up, fees, or other payments arising from loans extended to the Company for purposes of the design and construction of the Complex and the permanent financing provided to the Company for the Project pursuant to the Financing Documents. Notwithstanding the foregoing, the Parties acknowledge that OPIC is exempted from Liberian Taxes pursuant to the terms of a bilateral agreement between the GOL and the United States of America.
