# Local File: Helios Lane IP 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 IP Ltd is a company resident in Cyprus. Legal owner of the platform software; two employees, no engineers.
Group: Helios Lane Software. Entities in the group: Helios Lane Development Ltd (CY); Helios Lane IP Ltd (CY); Helios Lane Inc. (US).
Documentation duty: royalties and licences of €3,000,000 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 0fb19e4a3e905ad5eeba3ba80383968a2123a28edde24eb735f346548c250b22._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Licence of the platform software
Licence of the platform software: Helios Lane IP Ltd to Helios Lane Inc., €3,000,000 in the year.
Method: Comparable uncontrolled price, royalty rate. Tested party: Helios Lane IP 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: Platform licence agreement; checked against the file (1 point differs).
Risk allocation: Licensor bears the risk of the platform losing value.
Functional analysis: Helios Lane IP Ltd as the legal owner of the intangible without performing or controlling its development — its entitlement to the licence income beyond a return for its own functions is in question (DEMPE).

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash d8fe3472b094a75ebcfd2c69199a15998846535597c312f1faf4fe8d8ca79e23._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
No accounts for Helios Lane IP 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 26d61196a885fbf1b876eeade0e41dd1d912a10cb2dd3b88011b5638344f1606._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet