Engagements › Helios Lane Software › 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.

Helios Lane Development Ltd Helios Lane IP 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

Helios Lane Development Ltd is a company resident in Cyprus. Software development centre: 140 engineers in Limassol.

Group: Helios Lane Software. Entities in the group: Helios Lane Development Ltd (CY); Helios Lane IP Ltd (CY); Helios Lane Inc. (US).

Documentation duty: services of €10,600,000 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: Helios Lane Development Ltd (draft).

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Rests on, not yet confirmed: Obligations: Helios Lane Development Ltd.

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2.1 Contract software development

Draft

Contract software development: Helios Lane Development Ltd to Helios Lane Inc., €10,600,000 in the year.

Method: Transactional net margin method, net cost plus. Tested party: Helios Lane Development Ltd.

Interquartile range on 8 accepted comparables (inclusive quartiles): 7.30% to 9.18%, median 8.20%. Result of the tested party: 8.70%, within the range.

Within the range, so no transfer pricing adjustment is required (a suggestion until confirmed); but the agreement says 10.00% and the provider has invoiced €126,763 less than its own contract — invoice to the contract, or amend the agreement to the range: for the practice to decide. The written agreement is the starting point (OECD 1.42).

Written agreement: Development services agreement; checked against the file (1 point differs).

Risk allocation: The parent bears the risk that development fails.

Functional analysis: Helios Lane Development Ltd as a routine service provider, remunerated on its costs plus a mark-up.

Sources: OECD 3.57, 3.60; OECD 1.36; OECD 1.42. Rests on: Benchmarking: Contract software development (draft), Agreement: Contract software development (draft), Functional analysis: Contract software development (draft).

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Rests on, not yet confirmed: Benchmarking: Contract software development, Agreement: Contract software development, Functional analysis: Contract software development.

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Evidence still outstanding: Board minutes approving the development budget, due 11 Nov 2026 — in 4 days.

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

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3. Financial information

Draft

Financial information used in the analysis: Trial balance, Development Ltd (SHA-256 7805389c15b537f7…).

Contract software development: net cost plus earned 8.70%.

Sources: OECD Ch. V, Annexes I–II.

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