6.1.6 which arises in whole or in party (or which would have arisen but for the utilisation or set off of any Relief) in consequence of an Event occurring before, on or after Completion and for which the Company is liable for any reason as a result of (a) the failure by any person to pay Tax and (b) the Company having been a member of the same group of companies as, or otherwise connected or associated with, that person for any Tax purpose;