# Local File: Cobalt Bay Brands Ltd
Financial year 2025. Prepared with tp.alp for Cobalt Bay Resorts.

> **DRAFT — NOT SIGNED OFF.** 3 of 3 sections are not confirmed. Not for filing.

## 1. The local entity
Cobalt Bay Brands Ltd is a company resident in Cyprus. Owns and licenses the Cobalt Bay hotel brand.
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: royalties and licences of €1,620,000 exceeds the €1,000,000 threshold the Tax Department publishes.

_Sources: Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Tax Department, Frequently Asked Questions about Transfer Pricing, question 52; OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash d7aae925aeecc7efdc6f01ba8dff94d253ec4e2bcecb8c01ffe1cf5206f72d6e._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Brand licence to the hotels
Brand licence to the hotels: Cobalt Bay Brands Ltd to Cobalt Bay Hotels Hellas S.A., €1,620,000 in the year.
Method: Comparable uncontrolled price, royalty on room revenue. Tested party: Cobalt Bay Brands Ltd.
Royalty rate: licence-agreement search not yet run (requested from the database team). Until it is, the royalty rate is the policy's, not yet evidenced as arm's length.
Written agreement: Brand licence agreement; checked against the file (1 point differs).
Risk allocation: Licensor bears brand development risk.

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash 2bc7adfc5fadbffdbe3998485806e5aa1dd2d942bd9c5e2f83b2a4fe31746708._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
No accounts for Cobalt Bay Brands Ltd are on file yet: requested from the client.

_Sources: OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash 4f1314827071ceb73e364611199da387e48b1a1d59bcab488fd41ea572d8fb55._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet