A Tax Funding Agreement is essential for corporate groups operating in Ireland who wish to establish clear and legally compliant mechanisms for managing intra-group tax obligations. This document is typically used when multiple group companies need to coordinate their tax positions, share tax burdens and benefits, and ensure efficient tax administration within the group structure. The agreement becomes particularly important in contexts where groups need to manage tax consolidation, group relief, or shared tax responsibilities. It includes comprehensive provisions for calculating tax contributions, timing of payments, handling of tax refunds, and dealing with changes in group membership. The document must comply with Irish tax legislation, including the Taxes Consolidation Act 1997 and relevant EU directives, while also considering corporate law requirements under the Companies Act 2014.
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1. Parties: Identification of the head company and participating subsidiaries
2. Background: Context of the agreement, including group structure and purpose of the tax funding arrangement
3. Definitions and Interpretation: Key terms used throughout the agreement and interpretation rules
4. Tax Funding Obligations: Core provisions regarding payment obligations for tax liabilities and refunds
5. Calculation of Tax Funding Amounts: Methodology for calculating contributions and distributions
6. Payment Terms: Timing, method and currency of payments
7. Record Keeping and Information Sharing: Obligations regarding maintenance and sharing of tax records and information
8. Representations and Warranties: Standard representations regarding capacity and authority
9. Tax Administration: Procedures for tax returns, assessments, and dealings with tax authorities
10. Dispute Resolution: Procedures for resolving disagreements between group members
11. Termination: Circumstances and process for terminating the agreement
12. General Provisions: Standard boilerplate clauses including notices, amendments, and governing law
1. Foreign Currency Provisions: Required when group includes entities operating in different currencies
2. Tax Attributes: Needed when specific tax losses, credits, or other attributes need special treatment
3. VAT Grouping Provisions: Required when the group operates a VAT group registration
4. Exit Provisions: Detailed procedures for dealing with leaving entities, required for larger groups
5. Transitional Provisions: Required when replacing an existing tax funding agreement
6. Tax Consolidation Provisions: Specific provisions for consolidated tax groups if applicable
1. Schedule 1 - Group Members: List of all participating group companies and their details
2. Schedule 2 - Calculation Methodology: Detailed methodology for calculating tax funding amounts
3. Schedule 3 - Payment Procedures: Specific procedures and timelines for making payments
4. Schedule 4 - Pro-forma Calculations: Example calculations showing how the methodology works
5. Schedule 5 - Notice Forms: Template forms for various notices under the agreement
6. Schedule 6 - Deed of Accession: Template deed for new group members to join the agreement
7. Appendix A - Tax Accounting Principles: Agreed accounting principles for tax calculations
8. Appendix B - Dispute Resolution Procedures: Detailed procedures for handling disputes
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