tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Engagements › Cobalt Bay Resorts › Draft agreement: Guarantee of a €20,000,000 bank loan

Draft Agreement From The Policy

Guarantee of a €20,000,000 bank loan. Every clause is drafted from the transfer pricing policy and the functional analysis, and says where it came from. Anything the file does not settle is left open, in brackets.

Suggestion A draft, not an agreement. No signed agreement is on file for this transaction. It counts for nothing until it is confirmed, and then only as the practice's draft for the parties. Download As Text

  1. Guarantee fee agreement

    Between Cobalt Bay Resorts Holdings Ltd (the Guarantor) and Cobalt Bay Hotels Hellas S.A. (the Borrower).

    Source: Transaction record

  2. 1. The guarantee

    The Guarantor guarantees the Borrower's obligations to its bank up to €20,000,000.

    Source: Bank facility letter, guaranteed amount (invented)

  3. 2. Guarantee fee

    The Borrower pays the Guarantor a fee of [rate to be agreed] a year on the guaranteed amount — none is charged today. A guarantee is a financial transaction for the Tax Department (FAQ question 5).

    Source: Not in the file · open point

  4. 3. Payment

    Payment terms [to be agreed].

    Source: Group transfer pricing policy · open point

  5. 4. Risks

    [to be agreed: no risk analysis in the file]

    Source: Functional analysis, risks · open point

  6. 5. Arm's length

    The parties intend the terms to be at arm's length and will adjust them if a review shows they are not.

    Source: OECD Guidelines 1.6; Income Tax Law s.33(6)

  7. 6. Term and law

    Effective from 1 January of the year; [term, termination and governing law to be agreed by the parties].

    Source: Not in the file · open point

Sign-Off

ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Bank facility letter and any guarantee fee correspondence, due 30 Oct 2026 — 8 days overdue.

Evidence still outstanding: Accounts for 2025, Cobalt Bay Resorts Holdings Ltd, due 20 Nov 2026 — in 13 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash c359ffb7a808 · a change to it reopens every sign-off