Treaty Lender definition

Treaty Lender means a Lender which:

Treaty Lender means, in respect of a jurisdiction, a Lender entitled under the provisions of a double taxation treaty to receive payments of interest from a person resident in such jurisdiction without a Tax Deduction (subject to the completion of any necessary procedural formalities).

Treaty Lender means a Lender that:

Examples of Treaty Lender in a sentence

• A Treaty Lender and Funding 1 shall co-operate in completing any procedural formalities necessary for Funding 1 to obtain authorisation to make payments under the Funding 1 Liquidity Documents free and clear of and without deduction or withholding for or on account of any Taxes levied or imposed by the United Kingdom or any taxing authority of or in the United Kingdom.

• In particular, each Treaty Lender shall within the applicable time limits under the laws of the relevant jurisdiction complete, file and/or provide any tax certificate, treaty application or other document as may be reasonably requested by the relevant Borrower in writing in order for the Borrower to be able to make payments without a Tax Deduction.

• Each Lender which becomes a Party after the Effective Date shall indicate, in the Assumption Agreement or Assignment and Assumption that it executes on becoming a party hereto, and for the benefit of the Administrative Agent and without any liability to a Loan Party, which of the following categories it falls in: (A) an Irish Qualifying Lender (other than an Irish Treaty Lender); (B) an Irish Treaty Lender; or (C) not an Irish Qualifying Lender.

• No Obligor resident in the UK shall be liable to pay any sums to any Treaty Lender under Clause 10.1 (Gross-up) or Clause 10.2 (Indemnity) unless the Treaty Lender has complied with its obligations under this Clause 10.4(b).

• For the avoidance of doubt and only to the extent actually received by the relevant Treaty Lender, such refund shall be considered a Tax Credit and this Clause 16.4 shall apply in relation thereto to the extent that the refund is attributable to the increase in the amount paid by the Company pursuant to Clause 16.2.

More Definitions of Treaty Lender

Treaty Lender means a Lender which (a) is treated as a resident of a Treaty State for the purposes of the Treaty; (b) does not carry on a business in the United Kingdom through a permanent establishment with which that Lender’s participation in the Loans is effectively connected; and (c) fulfills any conditions subject to the completion of any necessary procedural formalities which must be fulfilled under the double taxation agreement for residents of that Treaty State to obtain exemption from United Kingdom taxation on interest.

Treaty Lender means a Lender which is, on the date a payment of interest falls due under this Agreement:

Treaty Lender means a Lender which is not a QPP Lender and which (a) is treated as resident of a Treaty State for the purposes of the relevant Treaty, (b) does not carry on a business in the United Kingdom through a permanent establishment with which the Lender’s participation in the Loans or Commitment is effectively connected and (c) which is entitled to claim the benefits of such Treaty with respect to payments made by any UK Borrower hereunder.

Treaty Lender means a Lender which is treated as a resident of a Treaty State for the purposes of the Treaty, does not carry on a business in the United Kingdom (in respect of a UK Qualifying Lender) or Germany (in respect of a German Qualifying Lender) through a permanent establishment with which that Lender’s participation in the Loans is effectively connected and meets all other conditions in the Treaty for full exemption from tax imposed on interest by the United Kingdom (in respect of a UK Qualifying Lender) or by Germany (in respect of a German Qualifying Lender).

Treaty Lender a Lender which:

Treaty Lender means a Lender which is (on the date a payment falls due), entitled to that payment under a double taxation agreement in force on the date (subject to the completion of any necessary procedural formalities) without a Tax Deduction.

Treaty Lender means, in respect of a UK Borrower, a Lender which: