Common use of Applicable Principles of Pillar Two Clause in Contracts

Applicable Principles of Pillar Two. To the extent that any Tax Attributes increase UTPR Taxes, but only to the extent that the UTPR Taxes reduce the Realized Tax Benefit (or increase the Realized Tax Detriment), the TRA Parties agree that PubCo and OpCo may make reasonable assumptions and estimates consistent with the purpose of this section to reduce administrative burdens on PubCo and OpCo when computing the effects of any UTPR Taxes on the Hypothetical Tax Liability; provided, however, that PubCo shall disclose any such assumptions or estimates in the Tax Benefit Schedule, and such assumptions and estimates shall be subject to the procedures set forth in Section 2.4.