Document background
The Intercompany Loan Agreement is essential for documenting financial arrangements between related companies within a corporate group under Dutch law. It is typically used when a parent company or group treasury entity provides financing to subsidiaries or sister companies, requiring careful consideration of transfer pricing rules, thin capitalization requirements, and corporate benefit principles. The document should be used whenever there is internal group lending to ensure proper documentation of the financial relationship, establish clear terms for the loan, and maintain compliance with Dutch tax and corporate law requirements. It includes comprehensive provisions covering loan terms, security arrangements, financial covenants, and governance requirements, while ensuring the transaction meets arm's length principles required by Dutch and international tax regulations.
