# Local File: Cobalt Bay Resorts Holdings 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 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: Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Tax Department, Frequently Asked Questions about Transfer Pricing, question 52; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10; OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash dfb19d4f9d36303fe76e87e4f61346a8bae6c864244ac4115d741f15c61a216b._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Guarantee of a €20,000,000 bank loan
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 Transfer Pricing Guidelines 2022, paragraph 1.36; OECD Transfer Pricing Guidelines 2022, paragraphs 10.161–10.177; Tax Department, Frequently Asked Questions about Transfer Pricing, question 5_
_Status: draft. Content hash b56b71878f46996bb5ea3f71a69ca2ac3e9c56da28a9a986a949e02edc847316._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
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 Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10_
_Status: draft. Content hash a11c35853d82a2f4bdb3d3253a8d53a860d4b4f0eaa0b0432330730e96db9e3b._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet