Taxation Liability in question. For this purpose, claims and elections are deemed to be valid if they would have been valid on the basis that Completion represented the end of an accounting period for tax purposes; 3.1.14 such Tax Liability is increased as a result of a failure of the Buyer to comply, or to comply promptly, with its obligations under this tax covenant except where such failure is carried out at the request or with the approval of the Covenantors;
3.1.15 such Tax Liability is covered by a Relief arising before Completion which is not a Buyer’s Relief;
3.1.16 such Tax Liability arises or is increased solely as a result of the Company becoming a member of the Buyer’s group for the purposes of any Tax;
3.1.17 such Tax Liability arises either from the cessation of any trade of the Company or a major change in the nature or conduct of any trade carried on by the Company, or by any trade becoming small or negligible, in each case occurring after Completion; 3.1.18 such Tax Liability is a fine, penalty, surcharge or interest arising by reason of any failure or delay on the part of the Company or the Buyer after Completion in paying to the relevant Tax Authority any payment made hereunder by the Covenantors, or in keeping, preserving, maintaining or submitting any records, returns, or computations after Completion;
3.1.19 such Tax Liability is stamp duty payable on the purchase of the shares in the Company by the Buyer;
3.1.20 such Tax Liability has already been successfully claimed under any other provisions of this Deed or the Agreement, including the Tax Warranties;
3.1.21 any member of the Buyer’s Group has already recovered from any third party any sum in respect of the Taxation Liability in question or that Taxation Liability has been otherwise settled;
3.1.22 such Taxation was discharged prior to Completion;
3.1.23 such Taxation Liability is caused by an originating timing difference as defined in Financial Reporting Standard Number 19;
3.1.24 such Taxation Liability comprises the loss or reduction of a Buyer’s Deferred Tax Relief where such loss or reduction is caused by an originating Timing Difference as defined in Financial Reporting Standard Number 19 such that a similar Relief becomes available to the Buyer or the Company; 3.2 The Covenantors shall have no liability in respect of any claim under this Deed unless notice of such claim shall have been served upon the Covenantors by the Buyer by no later than the seventh anniversary of Completion, unless the claim in question has arisen by reason of fraud on the part of the Covenantors, or prior to the Completion Date, on the part of the Company or any officer or representative of the Company, in which case there shall be no contractual limit on the time period within which such
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