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.

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Tax Structure Memorandum means the tax structure memorandum provided to the Agent referred to in paragraph 5 (Tax Structure Memorandum) of Part I (Conditions Precedent to Signing) of Schedule 2 (Conditions Precedent and Subsequent) (including, for the avoidance of doubt, any updated version provided to the Agent in accordance with the terms of that paragraph).

Tax Structure Memorandum means the tax structure memorandum titled “UK and Jersey corporation tax implications in respect of proposed Loan, Warrants and Options” prepared 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.
Cobham Ultra SunCo S.à ▇.▇., the direct Holding Company of the Company, identified as "Neptune SUNco" in the Tax Structure Memorandum.
Bidco: Cobham Ultra Acquisitions Limited, the entity identified as "Cobham Neptune Bidco" in the Tax Structure Memorandum.
The Company: Cobham Ultra SeniorCo S.à ▇.▇., the entity identified as "Neptune SeniorCo" in the Tax Structure Memorandum.
To the best of the knowledge, information and belief of the Company, all material factual information relating to the Group (taken as a whole) contained in the Tax Structure Memorandum is accurate in all material respects on the date of the relevant the Tax Structure Memorandum or (if different) as at the date ascribed thereto in the Tax Structure Memorandum.

More Definitions of Tax Structure Memorandum

Tax Structure Memorandum means the “Soho House Debt Restructuring: Accounting and Tax Considerations” report prepared by PricewaterhouseCoopers LLP delivered to the Original Notes Purchasers on or prior to the Closing Date.

Tax Structure Memorandum has the meaning given to that term in the Senior Facilities Agreement.

Tax Structure Memorandum means the final report relating to the Restructuring produced by ▇▇▇▇▇▇▇ & 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).

Tax Structure Memorandum means the Project ▇▇▇▇ – Tax Structure Memorandum dated July 24, 2014, prepared by ▇▇▇▇▇ and ▇▇▇▇▇. NY\6497185.2

Tax Structure Memorandum means the structure paper entitled “Project Casablanca—tax steps paper” and dated April 17, 2011, describing the Parent and each of its Subsidiaries from time to time (including the Carbon Black Subsidiaries) and the Primary Acquisition and prepared by KPMG LLP UK in the agreed form together with any updates thereto or reissuances thereof that are provided in accordance with the terms of the Revolving Credit Facility to the extent any such updates or reissuances do not have a material adverse effect on the rights of holders of the Notes.

Tax Structure Memorandum has the meaning assigned to such term in Section 4.01.