Treatment of Payments for Tax Purposes. For all Tax purposes, the Parties agree to treat (a) any payment required by this Agreement (other than payments with respect to interest accruing after the Effective Time) as either a contribution by Pentair to nVent Finance or a distribution by nVent Finance to Pentair, as the case may be, occurring immediately prior to the Effective Time or as a payment of an assumed or retained Liability; and (b) any payment of interest as taxable or deductible, as the case may be, to the Party entitled under this Agreement to retain such payment or required under this Agreement to make such payment, in either case except as otherwise required by applicable Law.
Appears in 4 contracts
Samples: Separation and Distribution Agreement, Separation and Distribution Agreement (PENTAIR PLC), Separation and Distribution Agreement (nVent Electric PLC)
Treatment of Payments for Tax Purposes. For all Tax tax purposes, the Parties agree to treat (ai) any payment required by this Agreement (other than payments with respect to interest accruing after the Effective Time) as either a contribution by Pentair Xxxxxxx Controls to nVent Finance Adient or a distribution by nVent Finance Adient to PentairXxxxxxx Controls, as the case may be, occurring immediately prior to the Effective Time or as a payment of an assumed or retained Liability; and (bii) any payment of interest as taxable or deductible, as the case may be, to the Party entitled under this Agreement to retain such payment or required under this Agreement to make such payment, in either case except as otherwise required by applicable Law.
Appears in 3 contracts
Samples: Separation and Distribution Agreement (Adient LTD), Separation and Distribution Agreement (Johnson Controls International PLC), Separation and Distribution Agreement (Adient LTD)