Taxes - GMSLA Provision: Difference between revisions

no edit summary
No edit summary
No edit summary
Line 1: Line 1:
{{gmslaanat|12}}
{{gmslaanat|12}}
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:
:“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)”
{{sa}}
*{{eqderivprov|Indemnifiable Tax}}