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

  • While the rebels were militarily much stronger in Balochistan, where tribal leaders had organized forces in the tens of thousands, the level of repression and violence were much lower than had been experienced in East Pakistan.In the previous section, I detailed the two causal pathways of the external security argument that can lead to variation in state response to secessionism.

  • DRP also observed that the VAS were ancillary and subsidiary to the application or enjoyment of right of the assessee in the brand used by the sightholders the payment for which was royalty in terms of para 3(a) of indo UK Tax Treaty and therefore its nature was that of fees for technical services.

  • The AO applied the rate of 15% under the provisions of Article-13 of India UK Tax Treaty.

  • The AO took the view that the payment received for the VAS was of the nature of fees for technical services both under the provisions of Income tax Act and under the provisions of Article-13 of India UK Tax Treaty and therefore taxable in India.

  • Example: Article 6 paragraph 2 – Singapore- UK Tax Treaty The term "international traffic" means all movements by a ship or aircraft operated by an enterprise of one of the Contracting States, other than movements solely between places in the other Contracting State or solely between such places and one or more structures used for the exploration or extraction of natural resources situated in waters adjacent to the territorial waters of that other Contracting State.

  • The assessee was thus providing technical services to the sightholders for their commercial purposes and the amount charged as VAS was nothing but fees for technical services within the meaning of Explanation-2 to Section- 9(1)(vii) and also under Article-13 of India UK Tax Treaty.

  • The AO has applied rate of 15% under provisions of Article-13 of India UK Tax Treaty.

  • The Indo UK Tax Treaty, employs the word “use or right to use” in contra distinction to the word ‘use’ in domestic law.

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

  • As per Article 5(2)(k) of the India- UK Tax Treaty a services PE of a non-resident is constituted where managerial or other services not covered under Article 13 (Royalty and FTS) are furnished in India through its employees for aggregate period of 30 days in the case of associated enterprises within any 12 month period.

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.

  • 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; and

  • 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, 1962 (Act No. 58 of 1962);

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

  • Transaction Tax Deductions means any Tax deductions relating to (i) any pay down or satisfaction of Company Indebtedness or other Indebtedness, (ii) the payment or incurrence of any Transaction Expenses or Transaction Bonus Payments and (iii) any other deductible payments attributable to the Contemplated Transactions economically borne by the Seller. For this purpose, any success-based fees shall be treated as deductible in accordance with Rev. Proc. 2011-29.

  • 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 withholding or deduction required pursuant to FATCA.

  • 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 Tax (a) based upon, measured by or calculated with respect to net income, profits or receipts (including, without limitation, capital gains Taxes and minimum Taxes) or (b) based upon, measured by or calculated with respect to multiple bases (including, without limitation, corporate franchise taxes) if one or more of the bases on which such Tax may be based, measured by or calculated with respect to, is described in clause (a), in each case together with any interest, penalties, or additions to such Tax.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.