Degrouping Taxation definition

Degrouping Taxation means any Tax arising as a result of any Target Group Company ceasing to be a member of a group or other association for Tax purposes with the relevant Seller or other Sellers’ Retained Group Company.
Sample 1Sample 2Sample 3
Degrouping Taxation means any Tax arising as a result of any Target Group Company ceasing to be a member of a group or other association for Tax purposes with the relevant Seller or other Sellers’ Retained Group Company. “Delayed Entities” has the meaning set forth in Section 10.2(c). “Derivative Transaction” means any swap transaction, option, warrant, forward purchase or sale transaction, futures transaction, cap transaction, floor transaction or collar transaction relating to one or more currencies, commodities, bonds, equity securities, loans, interest rates, catastrophe events, weather‑related events, credit‑related events or conditions or any indices, or any other similar transaction (including any option with respect to any of these transactions) or combination of any of these transactions, including collateralized mortgage obligations or other similar instruments or any debt or equity instruments evidencing or embedding any such types of transactions, and any related credit support, collateral or other similar arrangements related to such transactions. “Disadvantaged Person” has the meaning set forth in Section 8.3(k). “Disputed Items Notice” has the meaning set forth in Section 3.1(b). “Dormant Entities” means the entities that are marked with (*) on Exhibit 4.4(a), Exhibit 4.4(b), Exhibit 4.4(c) and Exhibit 4.4(d). “DPLA” and “DPLAs” have the meaning set forth in Section 8.3(a). “Dutch Xxxxx” means GMAC Nederland N.V. “Earning Assets” means, with respect to any Xxxxx or Fincos, the finance receivables and loans, net plus the leased vehicles, net plus the Restricted Cash, in each case of such Xxxxx or Fincos. “Effective Date” has the meaning set forth in Section 8.3(c). “Employee Benefit Plans” has the meaning set forth in Section 4.12(d). “Employee Matters” means any matters relating to Employees other than Tax matters relating to such Persons and any matters relating to the retirement benefits of such Persons under applicable Law or a Pension Plan. “Employees” means any of (i) the former and current employees of AOAG and the Assets Sellers as well as (ii) the former and current employees, legal representatives, directors and officers of any Target Group Company or any Controlled Dealership Entity.
Sample 1
Degrouping Taxation has the meaning given to it in the Tax Indemnity;
Sample 1

Examples of Degrouping Taxation in a sentence

  • The Sellers and the Purchaser undertake to enter into or procure that a member of the Sellers’ Group shall enter into, a Degrouping Election with each relevant Group Company substantially in the form shown in Schedule 15 on or prior to Closing in respect of any Degrouping Taxation for which any such Degrouping Election is capable of being made.

Related to Degrouping Taxation

  • Taxation means all forms of taxation, duties, rates, levies, contributions, withholdings, deductions, liabilities to account, charges and imposts whether imposed in the United Kingdom or elsewhere in the world;

  • Australian Tax Act means the Income Tax Assessment Act 1936 (Cth) (Australia) or the Income Tax Assessment Act 1997 (Cth) (Australia), as applicable.

  • criminal tax matters means tax matters involving intentional conduct whether before or after the entry into force of this Agreement which is liable to prosecution under the criminal laws of the requesting Party;

  • non-taxable territory means the territory which is outside the taxable territory;

  • casual taxable person means a person who occasionally undertakes transactions involving supply of goods or services or both in the course or furtherance of business, whether as principal, agent or in any other capacity, in the taxable territory where he has no fixed place of business;

  • School operating taxes means local ad valorem property taxes levied under section 1211 of the revised school code, MCL 380.1211, and retained for school operating purposes.

  • Qualifying tax rate means the applicable tax rate for the taxable year for the which the taxpayer paid income tax to a municipal corporation with respect to any portion of the total amount of compensation the payment of which is deferred pursuant to a nonqualified deferred compensation plan. If different tax rates applied for different taxable years, then the “qualifying tax rate” is a weighted average of those different tax rates. The weighted average shall be based upon the tax paid to the municipal corporation each year with respect to the nonqualified deferred compensation plan.

  • working tax credit means a working tax credit under section 10 of the Tax Credits Act 2002;

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).

  • Post-Closing Tax Period means any taxable period beginning after the Closing Date and, with respect to any Straddle Period, the portion of such Straddle Period beginning after the Closing Date.

  • Assigned Annual Special Tax means the Special Tax of that name described in Section D.

  • VAT Group means a group for the purposes of the VAT Grouping Legislation.

  • Integrated Goods and Services Tax Act means the Integrated Goods and Services Tax Act, 2017;

  • Post-Closing Taxes means Taxes of the Company for any Post-Closing Tax Period.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Actual Tax Liability means, with respect to any Taxable Year, the liability for Covered Taxes of the Corporation (a) appearing on Tax Returns of the Corporation for such Taxable Year and (b) if applicable, determined in accordance with a Determination (including interest imposed in respect thereof under applicable law).

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.

  • Public procurement unit means either a local public procurement unit or a state public procurement unit.

  • Annual Special Tax means the Special Tax actually levied in any Fiscal Year on any Assessor’s Parcel.

  • Pre-Closing Tax Returns has the meaning specified in Section 8.04(a).

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Goods and Services Tax or “GST” means the goods and services tax chargeable under the Goods and Services Tax Act (Cap. 117A);

  • goods and services tax practitioner means any person who has been approved under section 48 to act as such practitioner;

  • Significant emissions unit means an emissions unit that emits or has the potential to emit a PAL pollutant in an amount that is equal to or greater than the significant level (as defined in section 140 or in the Act, whichever is lower) for that PAL pollutant, but less than the amount that would qualify the unit as a major emissions unit as defined in section 079.

  • State premium tax liability means any liability