> **DRAFT — a suggestion, not signed off.** Not for signature.

## Loan agreement
Between Pinewood Street Finance Ltd (the Lender) and A director of Pinewood Street Finance Ltd (the Borrower).
_Source: Transaction record_

## 1. The loan
The Lender advances €400,000, repayable [term to be agreed] after drawdown.
_Source: Director's loan account, maximum in the year (invented)_

## 2. Interest
Interest accrues at [rate to be agreed] a year, payable quarterly in arrears.
_Source: Not in the file; group transfer pricing policy §3_

## 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_