Common use of Representations of the Lender Clause in Contracts

Representations of the Lender. The Lender represents that (a) it is a private limited liability company which at the date hereof is a resident of Ireland, is subject to taxation in Ireland on the basis of its registration as a legal entity, location of its management body or another similar criterion and it is not subject to taxation in Ireland merely on income from sources in Ireland or connected with property located in Ireland; and (b) on the assumption that entering into this Agreement and the transactions contemplated herein does not cause the Lender to have a permanent establishment in Russia, on the date hereof, it does not have a permanent establishment in Russia The Lender, at the cost of the Borrower, shall make reasonable and timely efforts to assist the Borrower to obtain relief from withholding of Russian income tax pursuant to the double taxation treaty between Russia and the jurisdiction in which the Lender is incorporated, including its obligations under Clause 8.8 (Delivery of Forms). The Lender makes no representation as to the application or interpretation of any double taxation treaty between Russia and the jurisdiction in which the Lender is incorporated.