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 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: ITL s.33(7)–(8); Tax Dept FAQ Q52; OECD Ch. V, Annexes I–II. Rests on: Obligations: Helios Lane IP Ltd (draft).

Sign-Off

ReviewedVerifiedConfirmed

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

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Accounts for 2025, Helios Lane IP 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 hash 0fb19e4a3e90 · a change to it reopens every sign-off

2.1 Licence of the platform software

Draft

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 1.36. Rests on: Agreement: Licence of the platform software (reviewed), Functional analysis: Licence of the platform software (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Agreement: Licence of the platform software, Functional analysis: Licence of the platform software.

Next: Reviewed, by a team member. Choose a person under View As to sign.

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

Evidence still outstanding: Accounts for 2025, Helios Lane IP Ltd, due 20 Nov 2026 — in 13 days.

Evidence still outstanding: Licence agreement comparables search, Licence of the platform software, 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 hash d8fe3472b094 · a change to it reopens every sign-off

3. Financial information

Draft

No accounts for Helios Lane IP Ltd are on file yet: requested from the client.

Sources: OECD Ch. V, Annexes I–II.

Sign-Off

ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Accounts for 2025, Helios Lane IP 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 hash 26d61196a885 · a change to it reopens every sign-off