Engagements › Pinewood Street Pharma › Draft agreement: Loan to the Greek distributor
Draft Agreement From The Policy
Loan to the Greek distributor. 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 Pinewood Street Finance Ltd (the Lender) and Pinewood Street Hellas S.A. (the Borrower).
Source: Transaction record
1. The loan
The Lender advances €3,000,000, repayable [term to be agreed] after drawdown.
Source: Loan agreement clause 2 (invented)
2. Interest
Interest accrues at 3.20% a year, payable quarterly in arrears.
Source: Loan agreement clause 4 (invented); group transfer pricing policy §3
3. Payment
Invoices are payable within 180 days.
Source: Group transfer pricing policy
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