Panavision Groups Foreign Tax. Shall mean (i) the aggregate foreign income tax, computed in a manner consistent with the computation of the Panavision Group's Federal Tax, as defined above, that any of Panavision's foreign Subsidiaries would have incurred with respect to each relevant foreign taxing jurisdiction for any Taxable Period for which any foreign Subsidiary of Panavision participates with any foreign Subsidiary of Parent (other than Panavision or any Subsidiary of Panavision) in the filing of a combined foreign
... income tax return with such jurisdiction if any such foreign Subsidiary of Panavision had filed with such jurisdiction a separate return (in a case where only one foreign member of the Panavision Group joins in the filing of such combined return) or a combined return including only those foreign members of the Panavision Group actually joining in such combined return (in a case where more than one foreign member of the Panavision Group joins in the filing of such combined return), and (ii) without duplication, any foreign tax (whether or not based on income) of the Panavision Group that any of Panavision's foreign Subsidiaries would have incurred with respect to each relevant foreign taxing jurisdiction for any Taxable Period for which any foreign Subsidiary of Panavision participates with any foreign Subsidiary of Parent (other than Panavision or any Subsidiary of Panavision) in the filing of a combined foreign tax return with such jurisdiction if any such foreign Subsidiary of Panavision had filed with such jurisdiction a separate return (in a case where only one foreign member of the Panavision Group joins in the filing of such combined return) or a combined return including only those foreign members of the Panavision Group actually joining in such combined return (in a case where more than one foreign member of the Panavision Group joins in the filing of such combined return). Notwithstanding the foregoing, if and to the extent any foreign Subsidiary of Panavision is compensated for the use of its tax attributes by any Subsidiary of Parent that is not a member of the Panavision Group, thereafter, such tax attributes shall not be taken into account for purposes of calculating the Panavision Group's Foreign Tax.
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