Splitco Tax Returns. (i) With respect to any Separate Return for which Splitco is responsible pursuant to Section 3.02(b), Splitco and the other members of the Splitco Group must (x) allocate Tax Items between any Separate Return for which Splitco is responsible and any related Combined Return that is filed with respect to the same Tax Year in a manner that is consistent with the reporting of such Tax Items on such related Combined Return and (y) make any applicable elections required under applicable Tax Law, necessary to effect such allocation. (ii) Splitco shall provide to Distributing a copy of a substantially completed draft of any Separate Return for which Splitco is responsible pursuant to Section 3.02(b) at least twenty business days prior to its due date (taking into account any extensions validly obtained), or in the case of a Separate Return with a due date (taking into account any extensions validly obtained) within twenty business days following the Distribution Date, as soon as is reasonably practicable before such due date. Distributing shall thereafter have the right to review and consent to such Separate Return, including Splitco’s compliance with Section 3.04(b); provided that Distributing shall not withhold its consent to the extent that the filing of the Separate Return will not result in any incremental Tax cost or other adverse Tax impact to the Distributing Group. Splitco shall provide to Distributing any information relating to any such Separate Return that is reasonably necessary for Distributing to be able to provide such consent pursuant to this Section 3.04(d)(ii).
Appears in 3 contracts
Sources: Tax Sharing Agreement, Tax Sharing Agreement (Liberty Latin America Ltd.), Tax Sharing Agreement (Liberty Latin America Ltd.)