Swiss Tax Rulings definition

Swiss Tax Rulings means (i) the Tax ruling to be filed with the Cantonal Tax Administration of Basel-Stadt in connection with the Merger confirming that the Merger has no Swiss corporate income tax consequences for the Company and Merger Sub, and confirming certain Swiss corporate income tax consequences for the Merger Sub such as the continued use of any tax-relevant losses carried forward and the continuation of any holding periods of participations for the purpose of the application of the participation exemption, (ii) the Tax ruling to be filed with the Swiss Federal Tax Administration in connection with the Offer and the Merger confirming that neither the Merger, including, for the avoidance of doubt, the payment of the Offer Price to the remaining Company shareholders, nor the Offer has Swiss Withholding Tax, Swiss issuance stamp Tax or Swiss securities transfer stamp Tax consequences, and (iii) a filing regarding the treaty eligibility of the Parent under Article 10 paragraph 2(a) of the Double Taxation Agreement Switzerland-USA;
Sample 1Sample 2Sample 3
Swiss Tax Rulings means the Basel-Stadt Tax Ruling, the Fribourg Tax Ruling and the SFTA Tax Ruling.
Sample 1Sample 2Sample 3
Swiss Tax Rulings means the Swiss Tax Ruling applications to be filed with the following divisions of the Swiss Federal Tax Authorities: (i) External Audit Division – Team Rulings (“Division Contrôle Externe – Team Rulings”); and (ii) Refund Division – Team 5 (“Division Remboursement – Equipe 5”).
Sample 1Sample 2

Examples of Swiss Tax Rulings in a sentence

  • Alcon failing to comply or causing or permitting any of its Affiliates to fail to comply with the facts and conditions stated in the Swiss Tax Rulings relating to Alcon and any of its Affiliates, including Alcon Pharmaceuticals Ltd.


More Definitions of Swiss Tax Rulings

Swiss Tax Rulings has the meaning ascribed thereto on Schedule A-2.
Sample 1Sample 2
Swiss Tax Rulings means those tax rulings described in Section 1.1(d) of the Company and ML Parties’ Disclosure Letter.
Sample 1

Related to Swiss Tax Rulings

  • 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 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.

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

  • 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.

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

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

  • Canadian Tax Act means the Income Tax Act (Canada) and the regulations thereunder, as amended from time to time.

  • FATCA Withholding Tax means any withholding or deduction required pursuant to FATCA.

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

  • Swiss Guidelines means the following guidelines issued by the Swiss Federal Tax Administration:

  • 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.

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

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

  • ITA means the Income Tax Act (Canada), as amended;

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

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

  • 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).

  • 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.

  • Swiss Guarantor means a Guarantor incorporated, or for tax purposes resident, in Switzerland.

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

  • 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. Annex 1 – Data Processing

  • Tax Ordinance means the Israeli Income Tax Ordinance [New Version], 1961, as amended.

  • U.S. Taxes means any present or future tax, assessment or other charge or levy imposed by or on behalf of the United States of America or any taxing authority thereof or therein.

  • 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 or “Taxes” means any federal, state, local or foreign income, gross receipts, property, sales, use, license, excise, franchise, employment, payroll, withholding, alternative or add on minimum, ad valorem, transfer or excise tax, or any other tax, custom, duty, governmental fee or other like assessment or charge of any kind whatsoever, together with any interest or penalty, imposed by any Governmental Entity.

  • Unpaid withholding tax means withholding tax due but not paid by the date the withholding tax is required to be paid under applicable law.