Examples of Group Relief in a sentence
It is also Group policy not to reimburse entities for Group Relief surrendered unless, on a stand-alone basis and assuming the entity were not in the Group, those losses are judged to have value to the entity generating the loss.
For the avoidance of doubt, except as expressly provided to the contrary herein, the amount of Taxes for which Xxxxxxx Controls or Adient, as applicable, is liable pursuant to this Section 2, Section 3 or otherwise under this Agreement shall be calculated without taking into account the utilization of any Adient Group Relief or Xxxxxxx Controls Group Relief, respectively.
A group, which for tax purposes consists of the parent company and all the subsidiaries where the company controls, directly or indirectly, at least 75% of the issued share capital would be entitled to transfer losses and offset them against profits among the companies of the Group, where the surrendering company and the claimant company are members of the same group for the whole of the tax year (Group Relief).
A late election under Article 32(4) (Group Relief), Article 40 (Election to Treat as an Expense), Article 82 (Election for Special Exempt Status) or Article 88 (Election for the Application of the Concessionary Rate) may be accepted by the Director of Tax where he is satisfied, on receipt of a written application for the purpose, that there was a reasonable cause why the election could not be made in time and it was made thereafter without unreasonable delay.
For the avoidance of doubt, the Parties shall be treated as agreeing and consenting to any surrenders arising in respect of any UK Group Relief arrangements for any Pre-Distribution Period notified between the Parties before the date of this Agreement.