6.9.3 the focus of the tax covenant will be to provide protection to the Buyer in respect of Tax Liabilities broadly by reference to the reduction which has occurred to the net assets arising from the additional tax in question;
6.9.4 the Buyer will not be burdened with making a series of claims in respect of a loss of a Deferred Tax Relief if the loss relates to the reduction in the capital allowance pools.
6.10 Due to this approach giving immediate credit for tax losses, it will not be appropriate if the tax losses carried forward at Completion are material when compared to the size of the transaction.
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