CLOSE COMPANIES. Any loans or advances made, or agreed to be made, by the Company within sections 455, 459 and 460 of CTA 2010 have been disclosed in the Disclosure Letter. The Company has not released or written off, or agreed to release or write off, the whole or any part of any such loans or advances.
CLOSE COMPANIES. 5.1 The Company is not and has not at any time been a close investment holding company within the meaning of section 34 CTA 2010.
5.2 The Company has not at any time during the period of seven years ending on the date of this agreement made any payment which falls to be treated as a distribution under section 1064 CTA 2010 (certain expenses of close companies treated as distributions).
5.3 The Company has not made or waived any loan, advance or payment or given any consideration which could fall to be chargeable to tax under chapter 3 of part 10 CTA 2010 (charge to tax in case of loan to a participator) and which have remained outstanding at any time during the period of seven years ending on the date of this Agreement and the Company has not released or written off or agreed to write off the whole of any such loans or advances.
5.4 The Company has not made any transfers of value (as specified in section 94(1) IHTA 1984) and there has been no variation in the Company’s share or loan capital within section 98 (Effect of alterations of capital) IHTA 1984. The Company is not liable for any Tax under section 199 (Dispositions by transferor) IHTA 1984.
CLOSE COMPANIES. The Company is not, nor has it ever been a close company within the meaning of Sections 414 and 415 of ICTA 1988.
CLOSE COMPANIES. The Company is not and has never been a close company within the terms of section 414 and 415 ICTA or sections 439 or 446 of the CTA 2010.
CLOSE COMPANIES. The Company is not, and has never been, a close company as defined in section 414 ICTA.
CLOSE COMPANIES. (a) No distribution within section 1064 of the CTA 2010 has been made by any Group Company since its Incorporation Date.
(b) No loan or advance made by or assigned to any Group Company falling within the provisions of sections 455, 459, and 460 of the CTA 2010 is outstanding or has been waived since the Management Accounts Date.
CLOSE COMPANIES. 6.1 Any loans or advances made, or agreed to be made, by the Company within sections 455, 459 and 460 of CTA 2010 have been disclosed in the Disclosure Letter. The Company has not released or written off, or agreed to release or write off, the whole or any part of any such loans or advances.
6.2 The Company is not a close-investment holding company (within the meaning of section 18N of CTA 2010).
CLOSE COMPANIES. (i) Neither the Company nor any Subsidiary is, nor has ever been, a close investment-holding company as defined in section 13A of ICTA 1988.
(ii) No distribution within section 418 of ICTA 1988 has been made by the Company or any Subsidiary during the last six years ending 19 February 2007, nor have such distributions been made between 19 February 2007 and Closing.
(iii) Any loans or advances made, or agreed to be made, by the Company or any Subsidiary within sections 419 and 420 or 422 of ICTA 1988 have been disclosed in Schedule 4.10(o). Neither the Company nor any Subsidiary has released or written off, or agreed to release or write off, the whole or any part of any such loans or advances.
CLOSE COMPANIES. 23.4.1 Close company status The Company has at all times been a close company within the meaning of sections 414 and 415, ICTA 1988.
23.4.2 Close investment-holding company status The Company has not in any accounting period beginning after 31/st/ March, 1989 been a close investment-holding company as defined in section 13A, ICTA 1988.
CLOSE COMPANIES. 4.1 The Company is not and has never been a close company within the meaning of Section 414 of the Taxes Act (close companies).
