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## Guarantee fee agreement
Between Cobalt Bay Resorts Holdings Ltd (the Guarantor) and Cobalt Bay Hotels Hellas S.A. (the Borrower).
_Source: Transaction record_

## 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)_

## 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_

## 3. Payment
Payment terms [to be agreed].
_Source: Group transfer pricing policy_

## 4. Risks
[to be agreed: no risk analysis in the file]
_Source: Functional analysis, risks_

## 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)_

## 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_