Swiss Tax Ruling definition

Swiss Tax Ruling means an advance tax ruling from the Federal Tax Administration of Switzerland addressing the Swiss tax consequences of certain aspects of the Transactions.
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Swiss Tax Ruling means a Tax ruling issued by the Swiss Taxing Authority to Seller or its Affiliates confirming a Swiss income Tax rate of less than the rate set forth on Schedule 6.11(a) to the Disclosure Letter shall be imposed on Seller or its Affiliates with respect to the Swiss Asset Transfer.
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Swiss Tax Ruling means the Tax rulings related to Xxxxx from the competent cantonal and federal Tax authorities determining whether [***]. “Target Amount” means an amount equal to (i) $[***] minus (ii) the Accrued Clinical Trial Costs. “Tax” or “Taxes” means any governmental income, gross receipts, premiums, profits, capital, franchise, withholding, payroll, employment, social security, workers compensation, unemployment, disability, property, ad valorem, stamp, excise, registration, occupation, service, sales, use, license, lease, transfer, import, export, customs, value added, severance, environmental, alternative or add-on minimum, estimated or other similar tax (including any fee, assessment, levy, tariff, charge, or duty in the nature of or in lieu of any tax), and any interest, penalties, additions, or additional amounts in respect of the foregoing, whether disputed or not. The term “Tax” includes, with respect to any Person, such Person’s liability for Taxes imposed on any consolidated or combined basis, and such Person’s obligations to indemnify or otherwise assume or succeed to the Tax liability of any other Person (other than pursuant to this Agreement). “Tax Holiday Decree” means that certain decree [***]. “Tax Return” means any return (including any information return), report, statement, schedule, notice, form, or other document or information filed with or submitted to, or required to be filed with or submitted to, any Governmental Body in connection with the determination, assessment, collection, or payment of any Tax or in connection with the administration, implementation, or enforcement of or compliance with any Law relating to any Tax.
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Examples of Swiss Tax Ruling in a sentence

  • The GE Entities agree that SES or its Affiliates shall negotiate the Swiss Tax Ruling after Closing if it has not been obtained prior to Closing.

  • The GE Entities will not knowingly effect any portion of the Leuk Workforce Reduction that would breach the Swiss tax holiday until after the Swiss Tax Ruling is obtained, provided that (i) it is apparent that the Swiss Tax Ruling will ultimately be obtained and (ii) the delay need not extend more than 90 days after the Closing Date.

  • Equipment The Customer purchases outright the indoor router unit and remains solely responsible for the replacement of the router in event of issues or damage to the router.

  • For the avoidance of doubt, the provisions of this Section 9.1(b) shall govern with respect to the interactions of the parties with the Swiss Tax Authority in connection with the Swiss Tax Ruling and Section 5.3(c) will not apply to the matters addressed in this Section 9.1(b).

  • In the event that a Swiss Taxing Authority refuses to issue a Swiss Tax Ruling, each of the Company and Parent shall consider in good faith any reasonable modifications to the structure of the transactions contemplated in this Agreement that will facilitate receipt of such rulings.

  • Alternatively, if the Parties so agree, and if such action enables Switzerland to retain the benefit of the Swiss Tax Ruling referred to in paragraph 8 below and does not affect the calculation of net debt under paragraph 6 Switzerland will sell the Consideration Shares at market value and transfer the proceeds of the sale to Butterfly.

  • Subject to the conditions specified in the tax ruling (the "Swiss Tax Ruling" dated August 6, 1999) received from the relevant tax authorities in Switzerland, the Butterfly de-merger will not be subject to Swiss taxes to Switzerland or Butterfly.

  • The Company has operated its business in compliance with the terms of the Swiss Tax Ruling received from the Canton de Vaud on November 4, 2004.

  • To the extent Seller receives, prior to the Closing, a Swiss Tax Ruling, the Purchase Price shall be reduced by an amount equal to the Swiss Sale Amount, less the sum of (i) the Estimated Swiss Gain and (ii) (x) the Estimated Swiss Gain multiplied by the Swiss Tax Rate, further multiplied by (y) the Swiss Gross-Up.

  • Switzerland and Butterfly will each indemnify the other for losses (and related costs) resulting from any action or inaction by it or by a third party with respect to it that causes the conditions to the Swiss Tax Ruling not to be satisfied.


More Definitions of Swiss Tax Ruling

Swiss Tax Ruling means:
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Related to Swiss Tax Ruling

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • Swiss Federal Tax Administration means the tax authorities referred to in article 34 of the Swiss Withholding Tax Act.

  • Swiss Withholding Tax Act means the Swiss Federal Act on Withholding Tax of 13 October 1965 (Bundesgesetz über die Verrechnungssteuer), together with the related ordinances, regulations and guidelines, all as amended and applicable from time to time.

  • Swiss Withholding Tax means any withholding tax in accordance with the Swiss Federal Statute on Anticipatory Tax of 13 October 1965 (Bundesgesetz uber die Verrechnungssteuer) and any successor provision, as appropriate.

  • IRS Ruling shall have the meaning set forth in the Recitals.

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

  • FATCA Withholding Tax means any U.S. federal withholding tax imposed or collected pursuant to Sections 1471 through 1474 of the Code, any current or future regulations or official interpretations thereof, any agreement entered into pursuant to Section 1471(b) of the Code, or any fiscal or regulatory legislation, rules or practices adopted pursuant to any intergovernmental agreement entered into in connection with the implementation of such Sections of the Code.

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

  • Issuer Tax Opinion means with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes and subject to customary assumptions and qualifications for opinions of this type, (a) such action will not adversely affect the tax characterization as debt of any Notes that were characterized as debt at the time of their issuance, and (b) following such action neither the Issuer nor the Titling Trust will be treated as an association (or publicly traded partnership) taxable as a corporation.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended.

  • Swiss Guidelines means, together, guideline S-02.123 in relation to interbank loans of 22 September 1986 (Merkblatt “Verrechnungssteuer auf Zinsen von Bankguthaben, xxxxx Xxxxxxxxx Xxxxxx sind (Interbankguthaben)” vom 22. September 1986), circular letter No. 47 in relation to bonds of 25 July 2019 (1-047-V-2019) (Kreisschreiben Nr. 47 “Obligationen” vom 25. Juli 2019), guideline S-02.130.1 in relation to money market instruments and book claims of April 1999 (Merkblatt vom April 1999 betreffend Geldmarktpapiere und Buchforderungen inländischer Schuldner), circular letter No. 46 of 24 July 2019 (1-046-VS-2019) in relation to syndicated credit facilities (Kreisschreiben Nr. 46 “Steuerliche Behandlung von Konsortialdarlehen, Schuldscheindarlehen, Wechseln und Unterbeteiligungen” vom 24. Juli 2019), circular letter No. 34 of 26 July 2011 (1-034-V-2011) in relation to deposits (Kreisschreiben Nr. 34 “Kundenguthaben” vom 26. Juli 2011), the circular letter No. 15 of 3 October 2017 (1-015-DVS-2017) in relation to bonds and derivative financial instruments as subject matter of taxation of Swiss federal income tax, Swiss withholding tax and Swiss stamp taxes (Kreisschreiben Nr. 15 “Obligationen und derivative Finanzinstrumente als Gegenstand der direkten Bundessteuer, der Verrechnungssteuer und der Stempelabgaben” vom 3. Oktober 2017) and the notification regarding credit balances in groups (Mitteilung 010-DVS-2019 of February 2019 betreffend “Verrechnungssteuer: Guthaben im Konzern”), each as issued, and as amended or replaced from time to time by the Swiss Federal Tax Administration, or as applied in accordance with a tax ruling (if any) issued by the Swiss Federal Tax Administration, or as substituted or superseded and overruled by any law, statute, ordinance, regulation, court decision or the like as in force from time to time.

  • Presumed Tax Rate means the highest effective marginal statutory combined U.S. federal, state and local income tax rate prescribed for an individual residing in New York City (taking into account (i) the deductibility of state and local income taxes for U.S. federal income tax purposes, assuming the limitation of Section 68(a)(2) of the Code applies and taking into account any impact of Section 68(f) of the Code, and (ii) the character (long-term or short-term capital gain, dividend income or other ordinary income) of the applicable income).

  • Swiss Guarantor means any Guarantor incorporated or organized under the laws of Switzerland.

  • Tax Law means the law of any governmental entity or political subdivision thereof relating to any Tax.

  • Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.

  • Withholding Tax means any tax, deduction, levy or similar payment obligation that is required to be deducted or withheld from a payment under Applicable Law.

  • Tax roll means a permanent record of the taxes charged on property, as extended

  • Excise Tax Act means the Excise Tax Act (Canada);

  • Canadian Tax Act means the Income Tax Act (Canada), as amended.

  • ITA means the Income Tax Act (Canada).

  • FATCA Withholding means any withholding or deduction required pursuant to an agreement described in section 1471(b) of the Code, or otherwise imposed pursuant to sections 1471 through 1474 of the Code, any regulations or agreements thereunder, any official interpretations thereof, or any law implementing an intergovernmental approach thereto.

  • Tax means any tax, levy, impost, duty or other charge or withholding of a similar nature (including any penalty or interest payable in connection with any failure to pay or any delay in paying any of the same).

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

  • Relevant Tax Authority means HMRC, or, if applicable, the tax authority in the jurisdiction in which the Supplier is established;

  • Post-Distribution Ruling has the meaning set forth in Section 7.02(c).

  • foreign tax means any Foreign Income Taxes or Foreign Other Taxes.