Engagements › Aegean Crest Shipping › Draft agreement: Guarantee of Shipping One's bank loan
Draft Agreement From The Policy
Guarantee of Shipping One's 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.
Guarantee fee agreement
Between Aegean Crest Navigation Inc. (the Guarantor) and Aegean Crest Shipping One Ltd (the Borrower).
Source: Transaction record
1. The guarantee
The Guarantor guarantees the Borrower's obligations to its bank up to €18,000,000.
Source: Bank facility letter for m/v Aegean Dawn: 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 · open point
3. Payment
Payment terms [to be agreed].
Source: Group transfer pricing policy · open point
4. Risks
[to be agreed: no risk analysis in the file]
Source: Functional analysis, risks · open point
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 · open point
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Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.
Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash59f0e35072e1 · a change to it reopens every sign-off