Group related definition

Group related means two or more entities which (i) directly or indirectly are controlled by the same group of shareholders or (ii) which are under common management.
View Source
Group related means two or more entities which (i) directly or indirectly are controlled by the same group of shareholders or (ii) which are under common management. Two parties may be considered to be group related by virtue of common management if they have the same manager or if they have different managers that have entered into an agreement providing for a common management of the lender and the borrower. In determining an arm's length price the approach taken in the OECD transfer pricing guidelines is generally applied.
View Source
Group related means two or more entities which (i) directly or indirectly are controlled by the same group of shareholders or (ii) which are under common management. The lender and the Danish borrower may be considered to be group related by virtue of common management if they have the same manager or if they have different managers that have entered into an agreement providing for a common management of the lender and the borrower. Not only taxable legal entities are considered as entities for purposes of group relation; also fiscally transparent entities may be considered if they are governed by rules of corporate law, a corporate law agreement or articles of association“. In practice, no filing claims apply to be exempt from withholding tax if the recipient is not group related with the borrower or if the recipient can claim exemption pursuant to (b) or (c), above. In the cases (d)-(f) a 25% tax is to be withheld at source and the recipient will need to reclaim the withholding tax by completing reclaim form 06.026 with the tax authorities enclosed with such documentation which substantiates eligibility for exemption under the relevant exception. According to a statement from the Danish ministry of taxation in 2000 the Danish tax authorities will confirm that also pension funds and investment funds are considered as tax residents in Denmark, irrespective of the fact that they do not pay corporate tax on their income.
View Source

Examples of Group related in a sentence

  • The cumulative aggregate liability of us and all of our affiliates and licensors to you the Customer and all of your Customer Group related under the Governing Agreement whether in contract tort or otherwise, will not exceed the amount of the fees paid or payable to us in the twelve (12) months immediately preceding the claim.

  • During the term of this Agreement, the Employee will create, develop and contribute for consideration certain ideas, plans, calculations, technical specifications, works of authorship, inventions, information, data, formulas, models, reports, processes, photographs, marks, designs, computer code, concepts and/or other proprietary materials to the Company Group related to the operation or promotion of the business of the Company Group (collectively, the “Work”).

  • By agreeing to these terms and conditions, you waive any provision under the laws and regulations of any jurisdiction that would, in the absence of such waiver, prevent or inhibit our compliance with applicable law as described in this paragraph including, but not limited to preventing (i) you from providing any requested information or documentation, or (ii) the disclosure by us or our Group related entities of the provided information or documentation to applicable governmental or regulatory authorities.

  • By agreeing to these terms and conditions, you waive any provision under the laws and regulations of any jurisdiction that would, in the absence of such waiver, prevent or inhibit our compliance with our obligations as described in this paragraph including, but not limited to preventing (i) you from providing any requested information or documentation, or (ii) the disclosure by us or our Group related entities of the provided information or documentation to applicable governmental authorities.

  • Notwithstanding the foregoing, the provisions of this Section 9 shall not be violated by (x) general advertising or solicitation not specifically targeted at Fairway Group related persons or entities or (y) Executive’s serving as a reference upon request.

  • Any legal action brought by Hut Group related to this Agreement may be brought by the Company and/or Hut jointly or individually.

  • These Operational Services may include both Seconded Services and other services that are performed by employees of the Licensee Group related to its own Assets.

  • Withdrawal requests from the Bank will be for the purposes of Agreement negotiations, executive meetings, training sponsored by the, Bargaining Group, and other Bargaining Group related purposes.

  • Parent and the members of the Parent Group shall have identical rights, and New Fluor shall have identical obligations, with respect to Audit Adjustment Requests by any member of the Parent Group related to (i) any Tax Period ending on or before, or which includes, the Distribution Date with respect to which a Separate Company Tax Return was filed by or on behalf of the Parent Group or any member thereof, and (ii) any Tax Period covered by a Consolidated or Combined Return.

  • Houston shall promptly forward to Seattle Group all trademark office correspondence received by the Houston Group and all trademark attorney and agent correspondence received by the Houston Group related to the Transferred Registered Trademarks for three hundred and sixty-five (365) days after the Distribution Date.