(c) the reduction or setting off against profits or against any Tax liability in respect of which a valid claim could have been made under this covenant of any Relief which is not available before Completion but arises in the Company after Completion (“ Post-Completion Relief ”).
(d) any Relief, whenever arising, of the Buyer or any member of the Buyer’s group other than the Company (“ Buyer’s Group Relief ”).
Deferred Tax Relief is still included within the definition of Buyer’s Relief: this collective noun is now only used in order to define a Seller’s Relief.
“Corresponding Saving”
This definition is no longer needed: most forms of Corresponding Saving will be represented by an Overprovision or Understatement. For those Corresponding Savings which fall outside this category, they are effectively included within the definition of Sellers’ Relief 1.2.3 “ Deferred Taxation ” means the estimated future tax consequences of the aggregate of the differences between the amounts of assets or liabilities in the Accounts and the amounts that are applicable for Tax purposes in accordance with International Accounting Standard 12 (IFRS), or “ Deferred Taxation ” means estimated future tax consequences of transactions and Events recognised in the Accounts in accordance with the provisions of Financial Reporting Standard 19; (UK GAAP).
These two definitions are extracted from the relevant accounting standards. Chapter 3 deals with various issues relating to Deferred Taxation.
1.2.4 “ Event ” includes any transaction, circumstance, state of affairs, act, event or omission of whatever nature;
1.2.5 “ IHT Liability ” means:
any reduction in the value of the net assets of the Company as a result of any amount of inheritance tax,
(i) in respect of which as at Completion, HM Revenue & Customs or any other person has a charge on or a power to sell, mortgage or charge any of the Shares or assets of the Company; or (ii) which after Completion becomes a charge on or gives rise to a power to sell, mortgage or charge any of the shares or assets of the Company being a liability in respect of inheritance tax payable as a result of the death of any person within seven years of a transfer of value if a charge on or power to sell,
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