Template:M summ GMSLA 12: Difference between revisions
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Amwelladmin (talk | contribs) Created page with "Expect some ninja swordplay on the extent of the gross up in {{gmslaprov|12.2(d)}}. For one thing, adding in some exemption for 871(m); another favourite trick is to..." |
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Expect some ninja swordplay on the extent of the [[gross up]] in {{gmslaprov|12.2(d)}}. | [[12 - GMSLA Provision|Expect]] some ninja swordplay on the extent of the [[gross up]] in {{gmslaprov|12.2(d)}}. | ||
For one thing, adding in some exemption for [[871(m)]]; another favourite trick is to try to harmonise with the {{isdaprov|Indemnifiable Tax}}es regime of the {{isdama}}, by carving out a [[gross up]] obligation to the extent it is a function of the gross-up recipient’s tax status with the withholding jurisdiction: | For one thing, adding in some exemption for [[871(m)]]; another favourite trick is to try to harmonise with the {{isdaprov|Indemnifiable Tax}}es regime of the {{isdama}}, by carving out a [[gross up]] obligation to the extent it is a function of the gross-up recipient’s tax status with the withholding jurisdiction: | ||
:“such Tax would not have been imposed but for a present or former connection between the jurisdiction imposing such Tax and the Recipient (other than the mere receipt of payment from Payer or the performance of Recipient’s obligations hereunder)” | :“such Tax would not have been imposed but for a present or former connection between the jurisdiction imposing such Tax and the Recipient (other than the mere receipt of payment from Payer or the performance of Recipient’s obligations hereunder)” | ||
Revision as of 17:16, 28 December 2020
Expect some ninja swordplay on the extent of the gross up in 12.2(d).
For one thing, adding in some exemption for 871(m); another favourite trick is to try to harmonise with the Indemnifiable Taxes regime of the ISDA Master Agreement, by carving out a gross up obligation to the extent it is a function of the gross-up recipient’s tax status with the withholding jurisdiction:
- “such Tax would not have been imposed but for a present or former connection between the jurisdiction imposing such Tax and the Recipient (other than the mere receipt of payment from Payer or the performance of Recipient’s obligations hereunder)”