Tax Structure Memorandum definition

Tax Structure Memorandum means the tax structure memorandum prepared by PricewaterhouseCoopers LLP entitled “Project Triton - Structuring Strawman Paper” in connection with the Transactions.
Tax Structure Memorandum has the meaning given to that term in the Senior Facilities Agreement.
Tax Structure Memorandum means the tax structure memorandum titled “UK and Jersey corporation tax implications in respect of proposed Loan, Warrants and Optionsprepared by Deloitte and delivered to the Agent pursuant to Clause 4.1 (Initial Conditions Precedent to the Utilisation).

Examples of Tax Structure Memorandum in a sentence

  • Holdco: Cobham Ultra Limited, the entity identified as "Neptune UK HoldCo" in the Tax Structure Memorandum.

  • The Company: Cobham Ultra SeniorCo S.à x.x., the entity identified as "Neptune SeniorCo" in the Tax Structure Memorandum.

  • Bidco: Cobham Ultra Acquisitions Limited, the entity identified as "Cobham Neptune Bidco" in the Tax Structure Memorandum.

  • Cobham Ultra SunCo S.à x.x., the direct Holding Company of the Company, identified as "Neptune SUNco" in the Tax Structure Memorandum.

  • US Co-Borrower: The entity identified as "US Co-Borrower" in the Tax Structure Memorandum.


More Definitions of Tax Structure Memorandum

Tax Structure Memorandum means the “Soho House Debt Restructuring: Accounting and Tax Considerationsreport prepared by PricewaterhouseCoopers LLP delivered to the Original Notes Purchasers on or prior to the Closing Date.
Tax Structure Memorandum means the final report relating to the Restructuring produced by Xxxxxxx & Marsal Taxand UK LLP dated on or around the date of this Deed addressed to LTD;
Tax Structure Memorandum has the meaning given to that term in Schedule 1 (Conditions Precedent). Additional Facility
Tax Structure Memorandum means the tax structure memorandum provided to the Interim Facility Agent under sub-paragraph 5 (Tax Structure Memorandum) of Part I (Conditions Precedent to Signing) of Schedule 3 (Conditions Precedent).
Tax Structure Memorandum means the document entitled "Project Warwick –Tax Acquisition Structure Report" dated 17 January 2024 prepared by Deloitte LLP in connection with the Acquisition.
Tax Structure Memorandum has the meaning assigned to such term in Section 4.01.
Tax Structure Memorandum means the tax structuring paper dated 24 June 2005 prepared by Deloitte & Touche LLP entitled “Project Toddler: Tax Structure Memorandum” relating to the Acquisition and the proposed changes in the Group structure occurring in anticipation of the Acquisition and following Closing and addressed to, and/or capable of being relied upon by, the Arrangers and the Finance Parties.