# Local File: Helios Lane Development Ltd
Financial year 2025. Prepared with tp.alp for Helios Lane Software.

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

## 1. The local entity
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: 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 f51287ec543a8141af7672984012fdf751c3edd4e51ea4d6f236ef51da9cfe8e._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Contract software development
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 Transfer Pricing Guidelines 2022, paragraphs 3.57, 3.60 (and 3.61–3.62); OECD Transfer Pricing Guidelines 2022, paragraph 1.36; OECD Transfer Pricing Guidelines 2022, paragraph 1.42 (and 1.43–1.46)_
_Status: draft. Content hash 58eae92aaaaa5caf56f292212108058c9e97f6d27501c0fe8bc9708ae8e75eef._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
Financial information used in the analysis: Trial balance, Development Ltd (SHA-256 7805389c15b537f7…).
Contract software development: net cost plus earned 8.70%.

_Sources: OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash a4d92ef3160b4caea8224eca4ba6b3098c474ce7d8309f4dfcc92fbfad122fff._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet