UK Tax Election Sample Clauses
UK Tax Election. The issuance of the Shares shall be conditional upon the Employee signing and returning to the Company a restricted securities election under Section 431 of the Income Tax (Earnings and ▇▇▇▇▇▇▇▇) ▇▇▇ ▇▇▇▇ in the form attached to this Agreement as Exhibit A (the purpose of this election being to advance any income tax and national insurance contributions charges arising in respect of the lapse of the resale restrictions on the Shares to the time of issuance of the Shares).
UK Tax Election. If, within the two year period starting on the last day of the accounting period of ▇▇▇▇▇▇ Limited current at the Relevant Closing Date, HMRC determines that the SSE is not available for ▇▇▇▇▇▇ Limited (or any other member of its group) in relation to the disposal of UK Newco, Sapphire (or the relevant member of its group) may at its discretion request that UK Newco shall promptly make a joint election with an Affiliate of Sapphire pursuant to section 792 of the United Kingdom Corporation Tax Act 2009 (“CTA09”) to reallocate the whole or part of any income deemed to arise on the deemed realization and reacquisition of any intangible assets of UK Newco falling to be taxed under Part 8 CTA09, in connection with the transfer of such intangible assets by ▇▇▇▇▇▇ Limited to UK Newco pursuant to the Restructuring such that such income is treated as arising to the relevant Affiliate of Sapphire rather than UK Newco (the “UK Tax Election”). The making of such a UK Tax Election does not prevent or restrict in any way ▇▇▇▇▇▇ Limited from legally challenging the HMRC determination and Buyer will cooperate in good faith to assist ▇▇▇▇▇▇ Limited in any such challenge.
UK Tax Election. If, within the two year period starting on the last day of the accounting period of ▇▇▇▇▇▇ Limited current at the Relevant Closing Date, HMRC determines that the SSE is not available for ▇▇▇▇▇▇ Limited (or any other member of its group) in relation to the disposal of Jewel UK Newco, Sapphire (or the relevant member of its group) may at its discretion request that Jewel UK Newco shall promptly make a joint election with an Affiliate of Sapphire pursuant to section 792 of the United Kingdom Corporation Tax Act 2009 (“CTA09”) to reallocate the whole or part of any income deemed to arise on the deemed realization and reacquisition of any intangible assets of Jewel UK Newco falling to be taxed under Part 8 CTA09, in connection with the transfer of such intangible assets by ▇▇▇▇▇▇ Limited to Jewel UK Newco pursuant to the Restructuring such that such income is treated as arising to the relevant Affiliate of Sapphire rather than Jewel UK Newco (the “UK Tax Election”). The making of such a UK Tax Election does not prevent or restrict in any way ▇▇▇▇▇▇ Limited from legally challenging the HMRC determination and Buyer will cooperate in good faith to assist ▇▇▇▇▇▇ Limited in any such challenge.