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1. Parties: Identification of the lender and borrower entities, including registration details and addresses
2. Background: Context of the intercompany loan and relationship between the parties
3. Definitions: Definitions of key terms used throughout the agreement
4. The Loan: Principal amount, currency, and purpose of the loan
5. Interest: Interest rate, calculation method, and payment frequency
6. Repayment Terms: Schedule for repayment, prepayment rights, and maturity date
7. Representations and Warranties: Standard corporate representations including authority, validity, and compliance with laws
8. Tax Provisions: Treatment of withholding tax, gross-up provisions, and tax compliance requirements
9. Events of Default: Circumstances constituting default and consequences
10. Notices: Communication requirements and contact details
11. Governing Law: Specification of Canadian law and jurisdiction
12. Execution: Signature blocks and execution requirements
1. Security: Include if the loan is to be secured by assets or guarantees
2. Guarantees: Include if there are parent company or third-party guarantees
3. Conditions Precedent: Include if disbursement is subject to specific conditions
4. Covenants: Include if specific ongoing obligations are required of the borrower
5. Assignment: Include if transfer rights need to be specifically addressed
6. Currency Conversion: Include for multi-currency loans or foreign currency payments
7. Subordination: Include if this loan needs to be subordinated to other debt
8. Transfer Pricing Compliance: Include detailed transfer pricing provisions if required by group policy
1. Repayment Schedule: Detailed amortization or payment schedule
2. Form of Draw Down Notice: Standard form for requesting loan disbursements
3. Transfer Pricing Documentation: Documentation supporting the arm's length nature of the loan terms
4. Security Details: Description of any security or collateral (if applicable)
5. Corporate Authorizations: Copies of relevant board resolutions and authorizations
6. Guarantees: Forms of any guarantees (if applicable)
7. Existing Indebtedness: Schedule of borrower's existing debt obligations
Financial Services
Manufacturing
Technology
Real Estate
Energy
Mining
Retail
Healthcare
Transportation
Telecommunications
Professional Services
Construction
Agriculture
Legal
Finance
Treasury
Tax
Compliance
Corporate Secretariat
Risk Management
Accounting
Corporate Development
Internal Audit
Chief Financial Officer
Treasury Manager
Tax Director
Corporate Controller
Finance Manager
Legal Counsel
Company Secretary
Financial Controller
Transfer Pricing Manager
Treasury Analyst
Tax Manager
Corporate Finance Director
Compliance Officer
General Counsel
Finance Director
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