The relevant alternative provision definition

The relevant alternative provision means the alternative provision which it is just and reasonable to assume would have been made or imposed as between the relevant company and one or more companies connected with that company, instead of the material provision, had tax (including any non-UK tax) on income not been a relevant consideration for any person at any time.
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The relevant alternative provision means the alternative provision which it is just and reasonable to assume would have been made or imposed as between the relevant company and one or more companies connected with that
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The relevant alternative provision. : This means the alternative provision that it is just and reasonable to assume would have been made or imposed, as between the relevant company and any connected companies, instead of the material provision, had tax on income not been a relevant consideration for any person at any time. The words “at any time” are designed to prevent companies from arguing that current (non-tax) synergies that were not anticipated when the structure was planned or implemented should be taken into account when determining whether the material provision in question would have been undertaken had tax not been a consideration. In other words, current unforeseen non-tax benefits cannot be used to justify historic and ongoing avoidance. An example illustration of the relevant alternative provision is outlined in DPT1330.
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More Definitions of The relevant alternative provision

The relevant alternative provision. : This means the alternative provision that it is just and reasonable to assume would have been made, rather than the material provision, as between the foreign company and any connected companycompanies had tax on income not been a relevant consideration for any person at any time. The words “at any time” are designed to prevent companies from arguing that current (non-tax) synergies that were not anticipated when the structure was planned or implemented should be taken into account when determining whether the material provision in question would have been undertaken
Sample 1
The relevant alternative provision. : This means the alternative provision that it is just and reasonable to assume would have been made or imposed, rather than the material provision, as between the relevant company and any connected company had tax on income not been a relevant consideration for any person at any time. The words “at any time” are designed to prevent companies from arguing that current (non-tax) synergies that may arise as a result of a structure originally set up to avoid tax cannot be taken into account when determining whether the material provision in question would have been undertaken had tax not been a consideration.
Sample 1
The relevant alternative provision. : This means the alternative provision that it is just and reasonable to assume would have been made, rather than the material provision, as between the foreign company and any connected company had tax on income not been a relevant consideration
Sample 1

Related to The relevant alternative provision

  • Aversive procedure means a systematic physical or sensory intervention program for modifying the behavior of a student with a disability which causes or reasonably may be expected to cause one or more of the following:

  • State Standard Agreement means the form used by the State to enter into agreements with other parties. Several originally signed, fully executed versions of the State Standard Agreement, together with the integrated Contract Documents, shall each represent the Agreement as an individual “Contract Counterpart.”

  • converted employment and support allowance means an employment and support allowance which is not income-related and to which a person is entitled as a result of a conversion decision within the meaning of the Employment and Support Allowance (Existing Awards) Regulations 2008;

  • Standard Terms and Conditions or “Standard Terms” means these terms and conditions for the grant of the Loan to the Borrower by ABFL.

  • Solar alternative compliance payment or "SACP" means a

  • Less restrictive alternative means court-ordered treatment in

  • Share Termination Alternative If applicable, Dealer shall deliver to Counterparty the Share Termination Delivery Property on, or within a commercially reasonable period of time after, the date when the relevant Payment Obligation would otherwise be due pursuant to Section 12.7 or 12.9 of the Equity Definitions or Section 6(d)(ii) and 6(e) of the Agreement, as applicable, in satisfaction of such Payment Obligation in the manner reasonably requested by Counterparty free of payment. Share Termination Delivery Property: A number of Share Termination Delivery Units, as calculated by the Calculation Agent, equal to the Payment Obligation divided by the Share Termination Unit Price. The Calculation Agent shall adjust the Share Termination Delivery Property by replacing any fractional portion of a security therein with an amount of cash equal to the value of such fractional security based on the values used to calculate the Share Termination Unit Price.

  • Optional Extended Local Calling Scope Arrangement Traffic is traffic that under an optional Extended Local Calling Scope Arrangement chosen by the Customer terminates outside of the Customer’s basic exchange serving area.

  • Terms-of-service agreement means an agreement that controls the relationship between a user and a custodian.

  • Relevant Terms and Conditions means terms and conditions relating to:

  • the Scottish Infected Blood Support Scheme means the scheme of that name administered by the Common Services Agency (constituted under section 10 of the National Health Service (Scotland) Act 1978(b));

  • Intent-Based Replacement Disclosure means, as to any Qualifying Preferred Stock or Qualifying Capital Securities, that the issuer has publicly stated its intention, either in the prospectus or other offering document under which such securities were initially offered for sale or in filings with the Commission made by the issuer under the Securities Exchange Act prior to or contemporaneously with the issuance of such securities, that the issuer will redeem or purchase such securities only with the proceeds of replacement capital securities that have terms and provisions at the time of redemption or repurchase that are as or more equity-like than the securities then being redeemed or repurchased, raised within 180 days prior to the applicable redemption or repurchase date. Notwithstanding the use of the term “Intent-Based Replacement Disclosure” in the definitions of “Qualifying Capital Securities” and “Qualifying Preferred Stock”, the requirement in each such definition that a particular security or the related transaction documents include Intent-Based Replacement Disclosure shall be disregarded and given no force or effect for so long as the Corporation is a bank holding company within the meaning of the Bank Holding Company Act of 1956, as amended.

  • Least restrictive alternative means the treatment and conditions of treatment which, separately and in combination, are no more intrusive or restrictive of freedom than reasonably necessary to achieve a substantial therapeutic benefit to the minor, or to protect the minor or others from physical injury;

  • Primary Terms and Conditions means the terms and conditions applicable to the ICICI Bank’s internet banking facility/service.

  • main phase employment and support allowance means an employment and support allowance where the calculation of the amount payable in respect of the applicant includes a component under section 2(1)(b) or 4(2)(b) of the Welfare Reform Act 2007 except in Part 1 of Schedule 1;

  • Additional Terms and Conditions means the terms and conditions that govern the promotion as determined by the Participating Banks (if any).

  • URL Terms means the terms with which Customer must comply, which are located at a URL, referenced in this Agreement and are hereby incorporated by reference.

  • General Terms and Conditions means the General Terms and Conditions for Services Contracts as referenced on the RFP cover page.

  • Specific Terms and Conditions means the specific terms and conditions as described in section 6.1 (and, in relation to an Agreement between Envestra and a Network User, means the Specific Terms and Conditions which form part of that Agreement).

  • Access Compensation is the compensation paid by one Party to the other Party for the origination/termination of intraLATA toll calls to/from its End User. Access compensation is in accordance with the LEC’s tariffed access rates.

  • Extended Terms shall have the meaning given such term in Section 2.4.

  • Period of Extended Hire means any additional period that the Hirer wishes the Agency Worker to be supplied for beyond the duration of the original Assignment or series of assignments as an alternative to paying a Transfer Fee;

  • STIPULATED HOURS OF SERVICE PER DAY means hours of duty per day, normal hours/timings of duty whereof shall be determined by the Company's Engineer for which fixed charge shall be payable.

  • Separate Terms refers to separate license terms that are specified in the Program Documentation, Service Specifications, readme or notice files and that apply to Separately Licensed Third Party Technology.

  • Normal weekly hours of work means the established standard work times and number of hours in the workweek for the position or, if standard work times and number of hours have not been established for the position, the work times and average number of hours per week actually worked by the employee in that position over the most recent 3 months before the employer files the application for designation as a participating employer.

  • Additional Day-ahead Scheduling Reserves Requirement means the portion of the Day- ahead Scheduling Reserves Requirement that is required in addition to the Base Day-ahead Scheduling Reserves Requirement to ensure adequate resources are procured to meet real-time load and operational needs, as specified in the PJM Manuals.