Common use of UK Group Relief Clause in Contracts

UK Group Relief. (a) Aptiv shall determine the amounts for purposes of UK Group Relief available to be surrendered (i) by any member of the Aptiv Group to any member of the Delphi Technologies Group, or (ii) by any member of the Delphi Technologies Group to any member of the Aptiv Group, as the case may be. (b) The Parties shall make, or shall cause to be made, such elections and shall take such other actions that are necessary or appropriate to give effect to the surrender of any amounts referred to in Section 3.07(a) to the extent permitted under applicable Law, and to ensure that such surrenders are allowed in full by HM Revenue & Customs. (c) In consideration of such surrenders as are referred to in Section 3.07(a)(i), Delphi Technologies shall procure that the relevant member of the Delphi Technologies Group shall pay to the relevant member of the Aptiv Group such amount of UK corporation Tax as is saved by the relevant member of the Delphi Technologies Group (including where UK corporation Tax previously paid has been refunded) as a result of the relevant surrender, such amount to be paid no later than the time which such UK corporation Tax saved would otherwise have been paid to a Tax Authority. (d) In consideration of such surrenders as are referred to in Section 3.07(a)(ii), Aptiv shall procure that the relevant member of the Aptiv Group shall pay to the relevant member of the Delphi Technologies Group such amount of UK corporation Tax as is saved by the relevant member of the Aptiv Group (including where UK corporation Tax previously paid has been refunded) as a result of the relevant surrender, such amount to be paid no later than the time which such UK corporation Tax saved would otherwise have been paid to a Tax Authority.

UK Group Relief. (a) Aptiv Parent shall determine the amounts for purposes of UK Group Relief available to be surrendered (i) by any member of the Aptiv Parent Group to any member of the Delphi Technologies SpinCo Group, or (ii) by any member of the Delphi Technologies SpinCo Group to any member of the Aptiv Parent Group, as the case may be. (b) The Parties shall make, or shall cause to be made, such elections and shall take such other actions that are necessary or appropriate to give effect to the surrender of any amounts referred to in Section 3.07(a) to the extent permitted under applicable Law, and to ensure that such surrenders are allowed in full by HM Revenue & Customs. (c) In consideration of such surrenders as are referred to in Section 3.07(a)(i), Delphi Technologies SpinCo shall procure that the relevant member of the Delphi Technologies SpinCo Group shall pay to the relevant member of the Aptiv Parent Group such amount of UK corporation Tax as is saved by the relevant member of the Delphi Technologies SpinCo Group (including where UK corporation Tax previously paid has been refunded) as a result of the relevant surrender, such amount to be paid no later than the time which such UK corporation Tax saved would otherwise have been paid to a Tax Authority. (d) In consideration of such surrenders as are referred to in Section 3.07(a)(ii), Aptiv Parent shall procure that the relevant member of the Aptiv Parent Group shall pay to the relevant member of the Delphi Technologies SpinCo Group such amount of UK corporation Tax as is saved by the relevant member of the Aptiv Parent Group (including where UK corporation Tax previously paid has been refunded) as a result of the relevant surrender, such amount to be paid no later than the time which such UK corporation Tax saved would otherwise have been paid to a Tax Authority.