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Engagements › Cobalt Bay Resorts › Local File

Local File

Assembled section by section for each entity that owes one. Each section shows what it rests on and where it stands. Content follows OECD Ch. V, Annexes I–II.

Assembled section by section; exports as final only when confirmed.

Cobalt Bay Resorts Holdings LtdCobalt Bay Brands Ltd

DRAFT — not signed off. 3 of 3 sections are not yet confirmed; an export now carries the draft mark. Export Draft On iPad: Print → Save as PDF for a readable copy. Export As Final — export as final once all 3 sections are confirmed, 3 to go

1. The local entity

Draft

Cobalt Bay Resorts Holdings Ltd is a company resident in Cyprus. Holding company and group management.

Group: Cobalt Bay Resorts. Entities in the group: Cobalt Bay Resorts Holdings Ltd (CY); Cobalt Bay Brands Ltd (CY); Cobalt Bay Hotels Hellas S.A. (GR).

Documentation duty: financing, by its maximum principal, of €20,000,000 exceeds the €5,000,000 threshold the Tax Department publishes.

Sources: ITL s.33(7)–(8); Tax Dept FAQ Q52; Tax Dept FAQ Q9–10; OECD Ch. V, Annexes I–II. Rests on: Obligations: Cobalt Bay Resorts Holdings Ltd (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Obligations: Cobalt Bay Resorts Holdings Ltd.

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Bank facility letter and any guarantee fee correspondence, due 30 Oct 2026 — 8 days overdue.

Evidence still outstanding: Accounts for 2025, Cobalt Bay Resorts Holdings Ltd, due 20 Nov 2026 — in 13 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash dfb19d4f9d36 · a change to it reopens every sign-off

2.1 Guarantee of a €20,000,000 bank loan

Draft

Guarantee of a €20,000,000 bank loan: Cobalt Bay Resorts Holdings Ltd to Cobalt Bay Hotels Hellas S.A., no fee charged, on a maximum guaranteed amount of €20,000,000.

Method: No guarantee fee charged; no written agreement. Tested party: Cobalt Bay Resorts Holdings Ltd.

A guarantee: no safe harbour rate applies.

No written agreement on file.

Risk allocation: Guarantor bears the risk of the hotel company defaulting.

Sources: OECD 1.36; OECD 10.161–10.177; Tax Dept FAQ Q5. Rests on: Financing: Guarantee of a €20,000,000 bank loan (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Guarantee of a €20,000,000 bank loan.

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Bank facility letter and any guarantee fee correspondence, due 30 Oct 2026 — 8 days overdue.

Evidence still outstanding: Accounts for 2025, Cobalt Bay Resorts Holdings Ltd, due 20 Nov 2026 — in 13 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash b56b71878f46 · a change to it reopens every sign-off

3. Financial information

Draft

No accounts for Cobalt Bay Resorts Holdings Ltd are on file yet: requested from the client.

Guarantee of a €20,000,000 bank loan: maximum guaranteed amount €20,000,000; no fee charged; tenor not on file.

Sources: OECD Ch. V, Annexes I–II; Tax Dept FAQ Q9–10.

Sign-Off

ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Bank facility letter and any guarantee fee correspondence, due 30 Oct 2026 — 8 days overdue.

Evidence still outstanding: Accounts for 2025, Cobalt Bay Resorts Holdings Ltd, due 20 Nov 2026 — in 13 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash a11c35853d82 · a change to it reopens every sign-off