Engagements › Aegean Crest Shipping › Draft agreement: Loan to the sister owner for a vessel purchase
Draft Agreement From The Policy
Loan to the sister owner for a vessel purchase. 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.
Loan agreement
Between Aegean Crest Navigation Inc. (the Lender) and Aegean Crest Navigation II Inc. (the Borrower).
Source: Transaction record
1. The loan
The Lender advances €6,500,000, repayable [term to be agreed] after drawdown.
Source: Loan note, maximum in the year (invented)
2. Interest
Interest accrues at 5.00% a year, payable quarterly in arrears.
Source: Loan note: 5% a year (invented); group transfer pricing policy §3
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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Hash
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