Group arrangements. 8.6.1. The Company has never been a member of any group of companies for any Taxation purpose. 8.6.2. The Company has not ceased to be a member of a group of companies for the purposes of sections 178 and 179 TCGA and will not cease to be a member of such a group as a result of Completion. 8.6.3. The Company has not at any time within the period of six years ending with the date of this agreement, acquired any assets other than trading stock from any company which, at the time of the acquisition, was a member of the same group (as defined in section 170 TCGA) as the Company. 8.6.4. The Disclosure Letter sets out full details of any surrender or agreement to surrender, or acceptance or agreement to accept the surrender, by the Company of any amount by way of group relief under the provisions of sections 402, 403 and 407 to 413 Taxes Act. 8.6.5. All claims for group relief made by the Company were valid and have been or will be allowed by way of relief from corporation tax and the Company is not and will not, as a result of anything done before the date of this agreement, become liable to make any payment for an amount surrendered by any other company under or in connection in with the provisions of section 402 Taxes Act. 8.6.6. The Company is not and has not at any time been party to any arrangement falling within section 410 Taxes Act. 8.6.7. The Company has not made or purported to make any election under section 247 Taxes Act. 8.6.8. The Company has not made nor received nor purported to make or receive any surrender of the benefit of ACT under section 240 Taxes Act. 8.6.9. The Company is not liable to be assessed to any Taxation under the provisions of section 190 TCGA.
Appears in 1 contract
Sources: Agreement for the Sale and Purchase of Shares (Pharmacopeia Inc)
Group arrangements. 8.6.1. 8.5.1 The Company has never been a member of any group of companies for any Taxation purposepurpose other than of the Group.
8.6.2. 8.5.2 The Company has not ceased to be a member of a group of companies for the purposes of sections 178 and 179 TCGA and will not cease to be a member of such a group as a result of Completion.
8.6.3. 8.5.3 The Company has not at any time within the period of six years ending with the date of this agreement, acquired any assets other than trading stock from any company which, at the time of the acquisition, was a member of the same group (as defined in section 170 TCGA) as the Company.
8.6.4. 8.5.4 The Disclosure Letter sets out full details of any surrender or agreement to surrender, or acceptance or agreement to accept the surrender, by the Company of any amount by way of group relief under the provisions of sections 402, 403 and 407 to 413 Taxes Act.
8.6.5. 8.5.5 All claims for group relief made by the Company were valid and have been or so far as the Vendors are aware will be allowed by way of relief from corporation tax and the Company is not and will not, as a result of anything done before the date of this agreement, become liable to make any payment for an amount surrendered by any other company under or in connection in with the provisions of section 402 Taxes Act.
8.6.6. 8.5.6 The Company is not and has not at any time been party to any arrangement falling within section 410 Taxes Act.
8.6.7. 8.5.7 The Company has not made or purported to make any election under section 247 Taxes Act.
8.6.8. 8.5.8 The Company has not made nor received nor purported to make or receive any surrender of the benefit of ACT under section 240 Taxes Act.
8.6.9. The Company is not liable to be assessed to any Taxation under the provisions of section 190 TCGA.
Appears in 1 contract
Sources: Share Purchase Agreement (Dollar Financial Group Inc)