Examples of Dutch Holdco in a sentence
Seller shall transfer to Dutch Holdco as a contribution in kind to pay-up the Dutch Holdco Common Shares issued as the Share Consideration, and Dutch Holdco shall accept from Seller, all of the issued and outstanding Company Shares (other than the Purchased Shares) by means of the execution of a notarial deed of transfer before the Civil Law Notary.(c) Closing Deliverables.
A new Section 7.08(d) is hereby added as follows: (d) SPAC shall not, without the prior written consent of Seller, permit or consent to any amendment, supplement or modification to any New Subscription Agreement or New Forward Purchase Agreement if such amendment, supplement or modification adversely impacts Seller, the Company or Dutch Holdco in any material respect.
However, Canadian courts agreed with the taxpayer that Dutch Holdco was not a mere conduit for the shareholders and, therefore, qualified for benefits under the Canada-Netherlands treaty.By contrast, in Indofood, the U.K. Court of Appeals held in favor of the government and disallowed treaty benefits on a beneficial ownership analysis.
The Queen,31 the U.K. case of Indofood International Finance Ltd.v. JPMorgan Chase Bank N.A., London Branch,32 and the French case of Société Bank of Scotland.33In Prévost, the Canadian Tax Court held that a Dutch holding company (Dutch Holdco) was the beneficial owner of dividends received from its Canadian subsidiary (Canadian Sub) for purposes of the Canada- Netherlands income tax convention.34 Under the treaty, Canadian Sub had withheld 5 percent tax on dividend payments to Dutch Holdco.
Merger Sub is a corporation organized under the laws of Delaware and a wholly owned subsidiary of Dutch Holdco.