Common use of Additional Tax Representation Clause in Contracts

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(d) is amended with respect to Party A only by the insertion of the following after the words “Clause 3(e) or (f)”: “or Part 5(6) of the Schedule”. Back to Contents

Additional Tax Representation. 6.1 (i) Party A makes the following representation (the Additional Tax RepresentationADDITIONAL TAX REPRESENTATION), which representation shall be deemed to be repeated at all times until the end of each Transaction: (aA) it is resident in the United Kingdom for United Kingdom tax purposes; or (bB) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timet▇▇▇); or▇▇ (cC) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timet▇▇▇). 6.2 Clause 5.1(d(▇▇) ▇▇▇▇▇▇▇ ▇(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 (i) Party A makes the following representation (the Additional Tax RepresentationADDITIONAL TAX REPRESENTATION), which representation shall be deemed to be repeated at all times until the end of each Transaction: (aA) it is resident in the United Kingdom for United Kingdom tax purposes; or (bB) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timeti▇▇); or▇▇ (cC) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timeti▇▇). 6.2 Clause 5.1(d(▇▇) ▇▇▇▇▇▇▇ ▇(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(dSection 5(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a branch or agency or permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) Section 697 of Schedule 26 to the Finance Corporation Tax ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 2 of the Income Taxation (International and Corporation Taxes Act 1988 Other Provisions) ▇▇▇ ▇▇▇▇ and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) Section 697 of Schedule 26 to the Finance Corporation Tax ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(dSection 5(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(d) is amended with respect to Party A only by the insertion of the following after the words “Clause 3(e) or (f)”: “or Part 5(65 (6) of the Schedule”. Back to Contents

Additional Tax Representation. 6.1 (i) Party A makes the following representation (the Additional Tax RepresentationADDITIONAL TAX REPRESENTATION), which representation shall be deemed to be repeated at all times until the end of each Transaction: (aA) it is resident in the United Kingdom for United Kingdom tax purposes; or (bB) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timet▇▇▇); or▇▇ (cC) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timet▇▇▇). 6.2 Clause 5.1(d(ii) Section 5(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(d) is amended with respect to Party A only by the insertion of the following after the words “Clause 3(e) or (for(f))”: “or Part 5(6) of the Schedule”. Back to Contents

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(d) is amended with respect to Party A only by the insertion of the following after the words “Clause 3(e) or (f)”: “or Part 5(6) of the Schedule”. Back to Contents.

Additional Tax Representation. 6.1 (i) Party A makes the following representation (the Additional Tax RepresentationADDITIONAL TAX REPRESENTATION), which representation shall be deemed to be repeated at all times until the end of each Transaction: (aA) it is resident in the United Kingdom for United Kingdom tax purposes; or (bB) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ Act 2002, as amended or re- enacted from time to ▇▇▇▇, as amended or re-enacted from time to time); or▇r (cC) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended mended or re-enacted from time to timeti▇▇). 6.2 Clause 5.1(d(▇▇) ▇▇▇▇▇▇▇ ▇(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 Party A makes the following representation (the Additional Tax Representation), which representation shall be deemed to be repeated at all times until the end of each Transaction: (a) it is resident in the United Kingdom for United Kingdom tax purposes; or (b) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇Ac▇ ▇▇▇▇, as amended or re-enacted from time to time); or (c) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇Ac▇ ▇▇▇▇, as amended or re-enacted from time to time). 6.2 Clause 5.1(dSection 5(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".

Additional Tax Representation. 6.1 (i) Party A makes the following representation (the Additional Tax RepresentationADDITIONAL TAX REPRESENTATION), which representation shall be deemed to be repeated at all times until the end of each Transaction: (aA) it is resident in the United Kingdom for United Kingdom tax purposes; or (bB) it is party to each Transaction solely for the purposes of a trade (or part of a trade) carried on by it in the United Kingdom through a permanent establishment and otherwise than as agent or nominee of another person (as those expressions are construed for the purposes of paragraph 31(6)(a) and (b) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-re- enacted from time to timet▇▇▇); or▇▇ (cC) it is resident in a jurisdiction that has a double taxation convention or treaty with the United Kingdom which has effect by virtue of section 788 of the Income and Corporation Taxes Act 1988 and under which provision, whether for relief or otherwise, in relation to interest (as defined in the relevant treaty or convention) is made and it is party to each Transaction otherwise than as agent or nominee for another person (as those expressions are construed for the purposes of paragraphs 31(7) and (8) of Schedule 26 to the Finance ▇▇▇ ▇▇▇▇Act 2002, as amended or re-enacted from time to timeti▇▇). 6.2 Clause 5.1(d(▇▇) ▇▇▇▇▇▇▇ ▇(a)(iv) is amended with respect to Party A only by the insertion of the following after the words “Clause "Section 3(e) or (f)”": “"or Part 5(6) of the Schedule”. Back to Contents".