definiens: , as defined under section 131D of the Israeli TaxOrdinance or ( iii ) has taken a as defined under Section 131E of the Israeli Tax Ordinance . NDXis in compliance with all transfer pricing requirements in all jurisdictions in which any of them do business ; none of thetransactions between or among NDX or any Affiliates may be subject to adjustment, apportionment, allocation orrecharacterization under Section 85A of the Israeli Tax Ordinance and the regulations promulgated thereunder or anylegal requirement, all of such transactions have been effected on an arm ’s length basis and NDX has made availableto CGI all material intercompany agreements, contracts and arrangements relating to transfer pricing . NDX is notsubject to restrictions or limitations pursuant to Part E2 of the Israeli Tax Ordinance pursuant to any Tax ruling madein connection with the provisions of Part E2