UK Tax Treaty definition

UK Tax Treaty has the meaning assigned to such term in the definition of “UK Treaty State”.
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UK Tax Treaty has the meaning assigned to such term in the definition of “UK Treaty State”. “UK Treaty Lender” means a Lender which: (a) is treated (subject to the completion of procedural formalities) as a resident of a UK Treaty State for the purposes of the relevant UK Tax Treaty, and (b) does not carry on a business in the United Kingdom through a permanent establishment with which that Lender’s participation in the Advance is effectively connected, and (c) fulfills any other conditions which must be fulfilled under the Treaty by residents of that UK Treaty State for such residents to obtain full exemption from taxation on interest imposed by the United Kingdom, subject to the completion of procedural formalities. “UK Treaty State” means a jurisdiction having a double taxation agreement (a “UK Tax Treaty”) with the United Kingdom which makes provision for full exemption from tax imposed by the United Kingdom on interest. “Unmatured Default” means an event which but for the lapse of time or the giving of notice, or both, would constitute a Default. “U.S. Borrower” means a Borrower that is organized in or under the laws of the United States or any political subdivision thereof. “U.S. Person” means any Person that is a “United States person” as defined in Section 7701(a)(30) of the Code. “U.S. Tax Compliance Certificate” is defined in Section 3.5(d).
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UK Tax Treaty has the meaning assigned to such term in the definition of “UK Treaty State”. “UK Treaty Lender” means a Lender which: (a) is treated (subject to the completion of procedural formalities) as a resident of a UK Treaty State for the purposes of the relevant UK Tax Treaty, and (b) does not carry on a business in the United Kingdom through a permanent establishment with which that Xxxxxx’s participation in the Advance is effectively connected, and (c) fulfills any other conditions which must be fulfileledfulfilled under the Treaty by residents of that UK Treaty State for such residents to obtain full exemption from taxation on interest imposed by the United Kingdom, subject to the completion of procedural formalities. “UK Treaty State” means a jurisdiction having a double taxation agreement (a “UK Tax Treaty”) with the United Kingdom which makes provision for full exemption from tax imposed by the United Kingdom on interest. “Unmatured Default” means an event which but for the lapse of time or the giving of notice, or both, would constitute a Default. “Unrestricted Cash” means, on any date, cash and cash equivalents owned on such date by the Consolidated Group, as would be reflected on a consolidated balance sheet of the Consolidated Group prepared as of such date in conformity with GAAP; provided that such cash and cash equivalents do not appear (and would not be required to appear) as “restricted” on a consolidated balance sheet of the Consolidated Group prepared in conformity with GAAP. “U.S. Borrower” means a Borrower that is organized in or under the laws of the United States or any political subdivision thereof. “U.S. Person” means any Person that is a “United States person” as defined in Section 7701(a)(30) of the Code. “U.S. Tax Compliance Certificate” is defined in Section 3.5(d). “Wholly-Owned Subsidiary” of a Person means (a) any Subsidiary all of the outstanding voting securities (other than (i) director’s qualifying shares and (ii) nominal shares issued to foreign nationals to the extent required by applicable law) of which shall at the time be owned or controlled, directly or indirectly, by such Person or one or more Wholly-Owned Subsidiaries of such Person, or by such Person and one or more Wholly-Owned Subsidiaries of such Person, or (b) any partnership, association, joint venture, limited liability company or similar business organization 100% of the ownership interests having ordinary voting power of which shall at the time be so owned or con...
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Examples of UK Tax Treaty in a sentence

  • The United States UK Tax Treaty covers double taxation with regards to figure tax at capital gains tax.

  • It has been further pointed out that the India-UK Tax Treaty was amended w.e.f. 11.02.1994 and in the Pre-amendment India- UK Tax Treaty ‘Managerial Services’ was specifically covered within definition of FTS but, however, under the Post amendment Treaty ‘Managerial Services’ are not included with the definition of FTS.

  • The AO observed that the subscription fee was in the nature of Royalty both under Section 9(1)(iv) of the Act as well as Article 13(3) of the India UK Tax Treaty.

  • Since, the definition of copyright is not available either under India – UK Tax Treaty and the domestic law, the Assessing Officer and learned Commissioner (Appeals) have heavily relied upon the definition of copyright as provided under the Copyright Act, 1957 and specifically the meaning of copyright as provided under section 14 of the Copyright Act.

  • The Council of State is an independent constitutional body whose advice is non-binding but will be made public if the bill is to be debated.The Boards have received legal advice that, if enacted in its current form, application of the bill to the Unification proposal would be in manifest breach of the obligations which the Dutch State has assumed under international law including under EU law, the Dutch UK Tax Treaty and the Convention for the Protection of Human Rights and Fundamental Freedoms.

Related to UK Tax Treaty

  • tax treaty means an agreement for the avoidance of double taxation entered into between South Africa and another country;

  • Intended Tax Treatment has the meaning set forth in the Recitals.

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

  • UK Tax Confirmation means a confirmation by a Lender that the person beneficially entitled to interest payable to that Lender in respect of an advance under a Loan Document is either:

  • Treaty means the Treaty establishing the European Community, as amended.

  • EC Treaty means the Treaty on the Functioning of the European Union (signed in Rome on 25 March 1957), as amended by the Treaty on European Union (signed in Maastricht on 7 February 1992) and as amended by the Treaty of Amsterdam (signed in Amsterdam on 2 October 1997), as further amended from time to time;

  • UK Tax Deduction means a deduction or withholding for, or on account of, Tax imposed by the United Kingdom from a payment under a Loan Document, other than a FATCA Deduction.

  • UK Treaty State means a jurisdiction having a double taxation agreement (a “UK Treaty”) with the United Kingdom which makes provision for full exemption from tax imposed by the United Kingdom on interest.

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

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

  • 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.

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

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

  • Transaction Tax Deductions means, to the extent Tax deductible for Income Tax purposes, all compensation attributable to payments by a Company or Company Subsidiary on or prior to the Closing Date, including employee transaction-related bonuses, change of control payments, and severance payments, resulting from or related to the consummation of the Contemplated Transactions that are charged to Sellers as part of the Transaction Expenses.

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

  • VATA means the Value Added Tax Xxx 0000;

  • Change in Tax Law means the enactment, promulgation, execution or ratification of, or any change in or amendment to, any law (or in the application or official interpretation of any law) that occurs on or after the date on which the relevant Transaction is entered into.

  • Relevant Tax Authority means HMRC, or, if applicable, the tax authority in the jurisdiction in which the Supplier is established;

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

  • FATCA Withholding Tax means any U.S. federal withholding tax imposed or collected pursuant to Sections 1471 through 1474 of the Code, any current or future regulations or official interpretations thereof, any agreement entered into pursuant to Section 1471(b) of the Code, or any fiscal or regulatory legislation, rules or practices adopted pursuant to any intergovernmental agreement entered into in connection with the implementation of such Sections of the Code.

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • Change in Tax Classification has the meaning set forth in Section 5.2(h).

  • 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.

  • 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).

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • Income Tax Return means any Tax Return relating to Income Taxes.