tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Engagements › Helios Lane Software › Obligations

Obligations

What each Cyprus entity owes for financial year 2025 — Local File, Summary Information Table (the Summary Table, for short), Master File — from its controlled transactions, each rule cited. Foreign entities are outside this practice's library and are not assessed here.

Which documents each Cyprus entity owes, each threshold cited.

Which threshold, for which year. For tax years 2022 to 2025 the Tax Department publishes €1,000,000 per category and €5,000,000 for financial transactions (Tax Dept FAQ Q52), above the statute's own €750,000 (ITL s.33(9)(α)). The conclusion follows the published thresholds; the statute is shown beside them. From tax year 2026 the law itself sets €2,500,000, €5,000,000 for goods and €10,000,000 for financing (L.244(I)/2025 s.17). A loan counts by its maximum principal in the year, not its interest (Tax Dept FAQ Q9–10).

Master File, for the group: only an Ultimate or Surrogate Parent Entity keeps one (ITL s.33(9)(β)), and a group under €750,000,000 of consolidated revenue is outside it (L.205(I)/2012 Annex III). On the revenue on file (€1,120,000,000 for 2024, US parent's consolidated accounts (invented), to be confirmed) the group is over €750,000,000: its ultimate parent keeps a Master File; none of the Cyprus companies is the ultimate parent — Helios Lane Inc. (US) is, so none of them keeps one here unless one is named the Surrogate Parent Entity — to be confirmed by the practice.

Country-by-country report, for 2025: the group is over €750,000,000 for 2024, so it reports. The Ultimate Parent Entity, Helios Lane Inc. (US), files where it is resident; whether a Cyprus company must file in its place (Annex III, Section II point 1) turns on that jurisdiction's rules and agreements with Cyprus — to be confirmed by the practice. Each Cyprus company notifies who files by 31 Dec 2025 — past; whether it was made is to be established; the report is due by 31 Dec 2026 (L.205(I)/2012 s.7Γ, L.205(I)/2012 Annex III §II.3–4, L.205(I)/2012 Annex III).

Helios Lane Development Ltd

Local File required

Software development centre: 140 engineers in Limassol

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Services (1 transaction)€10,600,000€1,000,000Yes€750,000Yes

Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).

Sign-Off

ReviewedVerifiedConfirmed

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

HashContent hash c837cd98ff9e · a change to it reopens every sign-off

Helios Lane IP Ltd

Local File required

Legal owner of the platform software; two employees, no engineers

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Royalties and licences (1 transaction)€3,000,000€1,000,000Yes€750,000Yes

Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).

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.

HashContent hash f080915d5d24 · a change to it reopens every sign-off