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The Intra Group Loan Agreement is essential for corporate groups operating in Ireland who need to establish formal lending arrangements between their related entities. This document is particularly important when implementing group treasury functions, managing internal capital allocation, or structuring internal financing. The agreement must comply with Irish corporate law requirements, particularly the Companies Act 2014, and address transfer pricing considerations under Irish tax law. It typically includes detailed terms about the loan facility, interest calculations, repayment provisions, and any security arrangements. The document is crucial for maintaining proper corporate governance and creating a clear audit trail for regulatory compliance, especially in contexts where the Irish Revenue Commissioners might review related party transactions.

1. Parties: Identification of the lender and borrower entities within the group structure

2. Background: Context of the intra-group loan, relationship between parties, and purpose of the loan

3. Definitions and Interpretation: Definitions of key terms and interpretation rules

4. The Facility: Details of the loan facility, including amount, purpose, and availability

5. Interest: Interest rate, calculation method, payment dates, and default interest provisions

6. Repayment: Terms of repayment, including schedule, prepayment rights, and mandatory prepayment events

7. Tax Provisions: Provisions for withholding tax, tax gross-up, and transfer pricing compliance

8. Representations and Warranties: Standard corporate representations and specific intra-group confirmations

9. Information Undertakings: Requirements for financial and other information provision

10. General Undertakings: Borrower's obligations regarding conduct of business and maintaining group status

11. Events of Default: Circumstances constituting default and consequences

12. Changes to Parties: Rules for assignment and transfer within the group

13. Administration: Mechanics for payments, calculations, and notices

14. Governing Law and Jurisdiction: Irish law as governing law and jurisdiction provisions