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Tax Sharing Agreement Template
"I need a Tax Sharing Agreement Template for a UAE-based holding company with five subsidiaries, including two free zone entities, to implement by January 2025 when we consolidate our group tax structure."
1. Parties: Identification of all parties to the agreement including their full legal names, registration numbers, and addresses
2. Background: Context of the agreement, relationship between parties, and purpose of the tax sharing arrangement
3. Definitions and Interpretation: Detailed definitions of technical terms, tax concepts, and interpretation rules
4. Tax Group Structure: Description of the corporate group structure and tax consolidation arrangement
5. Tax Sharing Principles: Core principles governing the allocation of tax liabilities and benefits
6. Calculation of Tax Contributions: Methodology for calculating each party's share of tax liability
7. Payment Terms and Procedures: Timing and method of tax payments, including interim payments and final settlements
8. Record Keeping and Information Sharing: Requirements for maintaining tax records and sharing relevant information
9. Tax Returns and Compliance: Responsibilities for preparing and filing tax returns and ensuring compliance
10. Dispute Resolution: Procedures for resolving disputes related to tax calculations or payments
11. Term and Termination: Duration of the agreement and circumstances for termination
12. General Provisions: Standard legal provisions including governing law, notices, and amendments
1. Free Zone Provisions: Special provisions for dealing with free zone entities and their specific tax treatment
2. International Tax Considerations: Provisions dealing with international tax implications when foreign entities are involved
3. VAT Specific Arrangements: Specific arrangements for sharing VAT liabilities and credits if relevant
4. Transfer Pricing Provisions: Specific provisions for handling transfer pricing adjustments and documentation
5. Tax Benefits Allocation: Methodology for sharing tax benefits, credits, and incentives
6. Exit Provisions: Detailed procedures for handling exit of group members from the tax sharing arrangement
7. Advance Rulings and Determinations: Procedures for handling tax authority rulings and determinations
1. Schedule 1 - Tax Allocation Formula: Detailed formula and methodology for calculating tax allocations
2. Schedule 2 - Payment Procedures: Detailed procedures for making tax payments and adjustments
3. Schedule 3 - Information Requirements: List of required information and documents to be shared between parties
4. Schedule 4 - Calculation Examples: Examples illustrating the application of the tax sharing calculations
5. Schedule 5 - Group Structure Chart: Diagram showing the corporate structure and tax consolidation arrangement
6. Appendix A - Compliance Calendar: Timeline of key tax compliance dates and deadlines
7. Appendix B - Contact Details: List of key contacts and their roles in tax administration
Authors
Adjusted Taxable Income
Allocation Percentage
Applicable Law
Business Day
Capital Gain
Compliance Obligations
Corporate Tax
Decree-Law
Deductible Expense
Effective Date
Excluded Income
Financial Year
Free Zone Person
Free Zone Qualifying Income
Group Head Entity
Group Member
Group Payment Arrangement
Head Company
Income Tax Liability
Mainland Entity
Net Tax Liability
Payment Date
Qualifying Group
Qualifying Revenue
Related Party
Relevant Period
Subsidiary Member
Tax Authority
Tax Benefit
Tax Credit
Tax Group
Tax Loss
Tax Payment
Tax Period
Tax Return
Tax Sharing Percentage
Taxable Income
Taxable Person
Transfer Pricing
UAE Corporate Tax
VAT
Working Day
Group Structure
Tax Consolidation
Payment Obligations
Calculation Methods
Record Keeping
Information Sharing
Compliance Requirements
Representations and Warranties
Confidentiality
Dispute Resolution
Force Majeure
Governing Law
Amendments
Termination
Notices
Assignment
Severability
Entire Agreement
Liability and Indemnification
Tax Administration
Default Provisions
Exit Mechanisms
Joining Procedures
Cost Allocation
Audit Rights
Authority and Capacity
Good Faith
Further Assurance
Tax Benefits Distribution
VAT Provisions
Free Zone Considerations
Transfer Pricing
Reporting Requirements
Documentation Requirements
Payment Mechanics
Tax Adjustments
Dispute Management
Review and Amendment
Counterparts
Financial Services
Manufacturing
Retail and Consumer
Real Estate and Construction
Technology and Communications
Energy and Resources
Healthcare and Pharmaceuticals
Professional Services
Logistics and Transportation
Hospitality and Tourism
Finance
Tax
Legal
Treasury
Compliance
Corporate Governance
Risk Management
Accounting
Internal Audit
Corporate Development
Chief Financial Officer
Tax Director
Financial Controller
Group Finance Manager
Tax Manager
Corporate Treasurer
Legal Counsel
Company Secretary
Finance Director
Head of Compliance
Head of Tax
Group Accountant
Financial Planning Manager
Risk Manager
Corporate Finance Manager
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