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Engagements › Cobalt Bay Resorts › Financing

Financing

The interest charged on each intra-group loan against the practice's yield analysis, with the working shown, and against the Tax Department's safe harbours where they apply.

Loans against the yield analysis and the Tax Department's safe harbours.

Guarantee of a €20,000,000 bank loan

Cobalt Bay Resorts Holdings Ltd guarantees a bank loan of Cobalt Bay Hotels Hellas S.A.

WorkingValueSource
Guaranteed amount€20,000,000Bank facility letter, guaranteed amount (invented)
Guarantee fee rate—None charged
Term—
Fee charged in the year€0Accounts not yet on file: requested from the client

Tax Department safe harbours Circular 6/2023

A guarantee, not a loan: no safe harbour rate applies. The benefit of group membership alone — implicit support — is passive association, for which no fee is payable; where the guarantee adds nothing beyond it, no fee is due. Where it adds something, the yield approach sets the maximum fee: the interest rate without the guarantee but with implicit support, less the rate with it OECD 10.161–10.177. Which applies here is a judgement for the practice on the facts. It counts as a financial transaction Tax Dept FAQ Q5.

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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.

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