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
1. The local entity
DraftCobalt 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: ITL s.33(7)–(8); Tax Dept FAQ Q52; OECD Ch. V, Annexes I–II. Rests on: Obligations: Cobalt Bay Brands Ltd (draft).
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ReviewedVerifiedConfirmedRests on, not yet confirmed: Obligations: Cobalt Bay Brands Ltd.
Next: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2025, Cobalt Bay Brands Ltd, due 20 Nov 2026 — in 13 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hashd7aae925aeec · a change to it reopens every sign-off2.1 Brand licence to the hotels
DraftBrand 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 1.36. Rests on: Agreement: Brand licence to the hotels (draft).
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ReviewedVerifiedConfirmedRests on, not yet confirmed: Agreement: Brand licence to the hotels.
Next: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2025, Cobalt Bay Brands Ltd, due 20 Nov 2026 — in 13 days.
Evidence still outstanding: Licence agreement comparables search, Brand licence to the hotels, due 21 Nov 2026 — in 14 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash2bc7adfc5fad · a change to it reopens every sign-off3. Financial information
DraftNo accounts for Cobalt Bay Brands Ltd are on file yet: requested from the client.
Sources: OECD Ch. V, Annexes I–II.
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2025, Cobalt Bay Brands Ltd, due 20 Nov 2026 — in 13 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash4f1314827071 · a change to it reopens every sign-off