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| {{gmslaanat|12}} | | {{Manual|MSG|2010|12|Clause|12|short}} |
| 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 favourtie 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:
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| :“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)”
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| {{sa}}
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| *{{isdaprov|Indemnifiable Tax}} under the {{isdama}}
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