Intra Group Loan Agreement Template for United States

An Intra Group Loan Agreement is essential for documenting financial arrangements between related entities in a corporate structure. This agreement, governed by U.S. law, ensures compliance with IRS regulations, particularly regarding transfer pricing and interest rates. It's commonly used when parent companies need to provide funding to subsidiaries, facilitate group treasury operations, or support expansion projects. The document must address federal requirements under IRC Sections 482 and 385, state lending laws, and corporate governance requirements while maintaining arm's length principles.

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

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

3. Definitions: Key terms used throughout the agreement including compliance with relevant US regulations and tax requirements

4. Loan Amount and Purpose: Specification of the loan amount and intended use

5. Interest Rate: Interest rate terms, including compliance with Applicable Federal Rate (AFR) requirements and state usury laws

6. Repayment Terms: Schedule and method of repayment, including provisions for early repayment

7. Representations and Warranties: Standard corporate confirmations from both parties including compliance with relevant US regulations

8. Events of Default: Circumstances constituting default and consequences

9. Governing Law: Applicable jurisdiction and law (US federal and state law provisions)