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Tax Sharing And Funding Agreement
"I need a Tax Sharing and Funding Agreement for our UAE holding company and its five subsidiaries, addressing the new corporate tax obligations starting January 2025, with specific provisions for quarterly funding mechanisms and intra-group loans."
1. Parties: Identification of all parties to the agreement, including tax collecting entities and recipients
2. Background: Context of the agreement, including relevant tax authority arrangements and basis for tax sharing
3. Definitions: Detailed definitions of terms used, including specific tax types, calculation periods, and funding mechanisms
4. Tax Sharing Arrangements: Core provisions detailing how tax revenues will be shared between parties, including calculation methodologies
5. Funding Obligations: Details of funding arrangements, including timing, payment methods, and currency
6. Payment Mechanics: Specific procedures for making payments, including bank account details and payment verification
7. Tax Calculations: Methodology for calculating tax shares and adjustments
8. Record Keeping and Reporting: Requirements for maintaining tax records and reporting obligations
9. Audit Rights: Provisions for auditing tax calculations and payments
10. Representations and Warranties: Standard representations regarding authority, compliance with laws, and tax status
11. Confidentiality: Provisions regarding confidentiality of tax information and agreement terms
12. Term and Termination: Duration of agreement and circumstances for termination
13. Dispute Resolution: Procedures for resolving disputes, compliant with UAE law
14. Governing Law and Jurisdiction: Specification of UAE law as governing law and jurisdiction
1. Group Reorganization Provisions: Optional section dealing with changes in group structure or ownership
2. Specific Emirate Provisions: Additional provisions specific to particular emirates when relevant
3. Foreign Currency Provisions: Specific provisions for handling multiple currencies in calculations and payments
4. Tax Reform Adaptation: Provisions for adapting to future changes in UAE tax laws
5. Transition Provisions: Temporary provisions for transitioning from previous arrangements
6. Inter-company Loan Provisions: Specific provisions for handling related party funding arrangements
7. Force Majeure: Provisions for handling unforeseen circumstances affecting tax collection or sharing
1. Schedule 1 - Tax Calculation Methodology: Detailed methodology for calculating tax shares
2. Schedule 2 - Payment Procedures: Specific procedures and timelines for making payments
3. Schedule 3 - Reporting Templates: Standard templates for tax sharing reports and calculations
4. Schedule 4 - Bank Account Details: Details of designated bank accounts for payments
5. Schedule 5 - Contact Details: Contact information for key personnel and authorized representatives
6. Appendix A - Tax Types Coverage: Detailed list of tax types covered under the agreement
7. Appendix B - Compliance Requirements: Summary of relevant UAE tax compliance requirements
8. Appendix C - Historical Tax Data: Reference data for previous tax sharing arrangements if applicable
Authors
Actual Tax Liability
Administrative Agent
Aggregate Group Tax Liability
Allocated Tax Amount
Business Day
Calculation Date
Commercial License
Contributing Member
Corporate Tax
Due Date
Effective Date
Estimated Tax Payment
Excise Tax
Federal Tax Authority
Final Tax Return
Fiscal Year
Funding Notice
Funding Obligation
Funding Payment
Group
Group Member
Head Entity
Income Tax Return
Initial Public Offering
Interest Rate
Loss Entity
Material Adverse Effect
Member State
Parent Entity
Payment Date
Payment Schedule
Permitted Jurisdiction
Profit Entity
Quarterly Payment
Receiving Entity
Reconciliation Period
Regulatory Authority
Related Party
Relevant Tax Amount
Scheduled Payment Date
Settlement Date
Subsidiary Entity
Tax Assessment
Tax Authority
Tax Benefit
Tax Credit
Tax Group
Tax Law
Tax Loss
Tax Payment
Tax Period
Tax Return
Tax Sharing Amount
Tax Year
Taxable Income
UAE Corporate Tax
UAE VAT
Value Added Tax
Payment Obligations
Funding Arrangements
Tax Returns and Filings
Record Keeping
Information Sharing
Audit Rights
Confidentiality
Representations and Warranties
Tax Adjustments
Default and Remedies
Force Majeure
Dispute Resolution
Governing Law
Jurisdiction
Assignment
Termination
Amendments
Severability
Entire Agreement
Notices
Indemnification
Group Reorganization
Tax Authority Dealings
Compliance
Currency
Set-off Rights
Further Assurance
Tax Reporting
Cost Allocation
Bank Accounts
Payment Mechanics
Interest Provisions
Term
Transition Arrangements
Financial Services
Manufacturing
Real Estate and Construction
Retail and Consumer Goods
Energy and Resources
Healthcare
Technology
Transportation and Logistics
Hospitality and Tourism
Professional Services
Finance
Legal
Treasury
Tax
Compliance
Corporate Secretariat
Internal Audit
Accounting
Risk Management
Corporate Development
Chief Financial Officer
Tax Director
Head of Treasury
Financial Controller
Group Finance Manager
Tax Manager
Corporate Counsel
Legal Director
Compliance Officer
Group Accountant
Treasury Manager
Senior Tax Analyst
Finance Director
Head of Legal
Company Secretary
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