Irish Treaty Lender definition

Irish Treaty Lender means, a Lender or Participant, as the case may be, that is a resident of an Irish Treaty State for the purposes of a Treaty and that does not carry on a business in Ireland through a permanent establishment with which a Loan under this Agreement is effectively connected and has obtained an authorisation from the Revenue Commissioners of Ireland under the relevant Treaty to receive payments of interest in respect of this Agreement without deduction of Irish tax and that authorisation is current.

Irish Treaty Lender means a Lender which: (a) is treated (subject to the completion of procedural formalities) as a resident of an Irish Treaty State for the purposes of the relevant Irish Tax Treaty, and (b) does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Advance is effectively connected, and (c) fulfills all other conditions which must be fulfilled under the Irish Tax Treaty by residents of that Irish Treaty State for such residents to obtain full exemption from taxation on interest imposed by Ireland, subject to the completion of procedural formalities.

Irish Treaty Lender means, in respect of an Irish Borrower, a Lender which:

Examples of Irish Treaty Lender in a sentence

• Each Lender which becomes a Party after the Effective Date shall indicate, in the Assumption Agreement or Assignment and Assumption that it executes on becoming a party hereto, and for the benefit of the Administrative Agent and without any liability to a Loan Party, which of the following categories it falls in: (A) an Irish Qualifying Lender (other than an Irish Treaty Lender); (B) an Irish Treaty Lender; or (C) not an Irish Qualifying Lender.

• The Company is not required to make any deduction on account of Irish tax from any payment it may make under any Loan Document to a Lender which is an Irish Qualifying Lender subject, in the case of an Irish Treaty Lender, to the completion of any necessary procedural formalities.

• Each Irish Qualifying Lender that becomes a Revolving Facility Lender after the date of this Agreement shall confirm for the benefit of the Administrative Agent and without liability to the Parent or an Irish Borrower whether it is (i) an Irish Qualifying Lender (other than an Irish Treaty Lender), (ii) an Irish Treaty Lender or (iii) not an Irish Qualifying Lender in the Assignment and Acceptance that it executes on becoming a Revolving Facility Lender.

• Each Lender which becomes a Party after the Second Amendment Effective Date shall indicate, in the Assumption Agreement or Assignment and Assumption that it executes on becoming a party hereto, and for the benefit of the Administrative Agent and without any liability to a Loan Party, which of the following categories it falls in: (A) an Irish Qualifying Lender (other than an Irish Treaty Lender); (B) an Irish Treaty Lender; or (C) not an Irish Qualifying Lender.

• Company which makes a payment to which that Irish Treaty Lender is entitled shall co-operate in completing any procedural formalities necessary for the Company to obtain authorisation to make that payment without a Tax Deduction.

More Definitions of Irish Treaty Lender

Irish Treaty Lender means a Lender which is treated as a resident of an Irish Treaty State for the purposes of the Treaty, does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Loan is effectively connected and meets all other conditions in the relevant Treaty for full exemption from tax imposed by Ireland on interest (assuming the completion of any necessary procedural formalities).

Irish Treaty Lender means a Lender Party (other than a Lender falling within paragraph (b), (c), (d) or (e) of the definition of “Irish Qualifying Lender”) which is on the date any relevant payment is made, is entitled (subject to provision of the relevant self-certificate form) under a Treaty in force on that date to that payment without any Irish Tax Deduction.

Irish Treaty Lender means a Lender, other than a Lender falling within paragraph (b) of the definition of “Irish Qualifying Lender” which, subject to the completion of all necessary procedural formalities:

Irish Treaty Lender means a Lender which:

Irish Treaty Lender means a Lender, which on the date any relevant payment is made:

Irish Treaty Lender means a Lender which is on the date the relevant payment is made entitled under a double taxation agreement (an “Irish Treaty”) in force on that date between Ireland and another jurisdiction to that payment without any withholding for or on account of Irish Tax (subject to the completion of any procedural formalities) and which does not carry on a business in Ireland through a permanent establishment with which that Lender’s participation in the Loan is effectively connected.

Irish Treaty Lender a Person who: