Belgian Qualifying Lender means in respect of any interest payment made by a Belgian Borrower, a Lender which is beneficially entitled to it and which is: (a) a professional investor within the meaning of Article 105, 3° of the Royal Decree implementing the Belgian Income Tax Code (the “RD/BITC”), which is a company resident for tax purposes in Belgium or which is acting through a permanent establishment in Belgium with which the Loan is effectively connected; (b) a credit institution within the meaning of article 105, 1°, a) of the RC/BITC, which is a resident for tax purposes in Belgium or which is acting through a permanent establishment in Belgium; (c) a credit institution within the meaning of article 107, §2, 5, a), second dash of the RD/BITC, that is acting through its head office and is resident for tax purposes in a country with which Belgium has entered into a double taxation agreement that is in force (irrespective of whether or not the double taxation agreement makes provision for exemption from tax imposed by Belgium) or in a country which is a member state of the European Economic Area; (d) a credit institution within the meaning of article 107, §2, 5, a), second dash of the RD/BITC, that is acting through a permanent establishment which (i) itself qualifies as a credit institution within the meaning of the aforementioned article 107, §2, 5, a) second dash and (ii) is located in a country with which Belgium has entered into a double taxation agreement that is in force (irrespective of whether or not the double taxation agreement makes provision for exemption from tax imposed by Belgium) or in a country which is a member state of the European Economic Area; or (e) a Belgian Treaty Lender.
Belgian Qualifying Lender means, in respect of any interest payment made by a Belgian Borrower under any Loan Document, a Lender which is beneficially entitled to receive payments of interest under this Agreement without withholding tax (précompte mobilier/ roerende voorheffing) due to being:
Belgian Qualifying Lender means a Lender which is beneficially entitled to receive any interest payment made in respect of a Loan by a Belgian Obligor without a Tax Deduction due to being:
More Definitions of Belgian Qualifying Lender
Belgian Qualifying Lender means, in respect of any interest payment made by Belgian Borrower under this Agreement, a Lender which is beneficially entitled to interest payable to that Lender, and which is:
Belgian Qualifying Lender means a Lender which is:
Belgian Qualifying Lender means a Eurocurrency Lender or an Affiliate of a Eurocurrency Lender, which is beneficially entitled to payments of interest from a Belgian-resident Loan Party under a Loan Document and able to receive such payments free of Belgian Withholding Tax in its capacity as a Credit Institution acting through an establishment (whether its head office or a local office with which its participation in the Loan is effectively connected) located in a member state of the European Economic Area or in a jurisdiction with which Belgium has concluded a double taxation agreement which is in force on the date of interest payment.