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Engagements › Meridian Orchard Group › Functional Analysis

Functional Analysis

For each transaction, the questions the team asks, who performs each function, owns each asset and bears each risk, and where each answer came from. The narrative and the characterisation are drafted from the answers, as a suggestion. The factors: OECD 1.36.

Who performs, owns and bears what — and the narrative drafted from it.

Shared services to Germany

Meridian Orchard Shared Services Ltd → Meridian Orchard Trading GmbH · €1,840,000

AreaQuestionShared Services LtdTrading GmbHSource
FunctionsWho decides what services are ordered?LowHighInterview notes (Organisation chart and management interview notes)
FunctionsWho decides how the services are delivered?HighLowInterview notes (Organisation chart and management interview notes)
FunctionsWho employs the people who perform them?HighNoneInterview notes: 31 staff in Limassol (Organisation chart and management interview notes)
AssetsWho owns the systems and licences used?MediumLowInterview notes (Organisation chart and management interview notes)
RisksWho bears the risk that the services are not needed?LowHighServices agreement clause 5.2
RisksWho bears the risk of the services being performed badly?MediumLowServices agreement clause 5.2

Suggestion Drafted narrative. It counts for nothing until the item is confirmed.

Meridian Orchard Shared Services Ltd decides how the services are delivered; employs the people who perform them; owns the systems and licences used; and bears the risk of the services being performed badly.

Meridian Orchard Trading GmbH decides what services are ordered; and bears the risk that the services are not needed.

Of the 6 points, Shared Services Ltd leads on 4 and Trading GmbH on 2.

Suggested characterisation: Meridian Orchard Shared Services Ltd as a routine service provider, remunerated on its costs plus a mark-up.

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Shared services to Greece

Meridian Orchard Shared Services Ltd → Meridian Orchard Foods Hellas S.A. · €920,000

AreaQuestionShared Services LtdFoods Hellas S.A.Source
FunctionsWho decides what services are ordered?LowHighInterview notes (Organisation chart and management interview notes)
FunctionsWho decides how the services are delivered?HighLowInterview notes (Organisation chart and management interview notes)
FunctionsWho employs the people who perform them?HighNoneInterview notes: 31 staff in Limassol (Organisation chart and management interview notes)
AssetsWho owns the systems and licences used?MediumLowInterview notes (Organisation chart and management interview notes)
RisksWho bears the risk that the services are not needed?LowHighServices agreement clause 5.2
RisksWho bears the risk of the services being performed badly?MediumLowServices agreement clause 5.2

Suggestion Drafted narrative. It counts for nothing until the item is confirmed.

Meridian Orchard Shared Services Ltd decides how the services are delivered; employs the people who perform them; owns the systems and licences used; and bears the risk of the services being performed badly.

Meridian Orchard Foods Hellas S.A. decides what services are ordered; and bears the risk that the services are not needed.

Of the 6 points, Shared Services Ltd leads on 4 and Foods Hellas S.A. on 2.

Suggested characterisation: Meridian Orchard Shared Services Ltd as a routine service provider, remunerated on its costs plus a mark-up.

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Intra-group loan to Germany

Meridian Orchard Treasury Ltd → Meridian Orchard Trading GmbH · €882,000

AreaQuestionTreasury LtdTrading GmbHSource
FunctionsWho decides to lend, and on what terms?HighLowGroup transfer pricing policy §3
FunctionsWho monitors the borrower and the loan?MediumNoneInterview notes (Organisation chart and management interview notes)
AssetsWho provides the capital?HighNoneLoan agreement clause 2.1 (Loan agreement — Trading GmbH)
RisksWho bears the credit risk?HighNoneLoan agreement clause 6.1 (Loan agreement — Trading GmbH)
RisksWho bears the interest-rate risk on a fixed rate?MediumLowLoan agreement clause 4.1 (Loan agreement — Trading GmbH)

Suggestion Drafted narrative. It counts for nothing until the item is confirmed.

Meridian Orchard Treasury Ltd decides to lend, and on what terms; monitors the borrower and the loan; provides the capital; bears the credit risk; and bears the interest-rate risk on a fixed rate.

Of the 5 points, Treasury Ltd leads on 5 and Trading GmbH on 0.

Suggested characterisation: Meridian Orchard Treasury Ltd as a lender that controls and bears the credit risk.

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Evidence still outstanding: Loan drawdown notice and interest statements, due 13 Nov 2026 — in 6 days.

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

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Purchase of juices and preserves

Meridian Orchard Foods Hellas S.A. → Meridian Orchard Distribution Ltd · €6,300,000

AreaQuestionFoods Hellas S.A.Distribution LtdSource
FunctionsWho sets selling prices in the territory?NoneMediumInterview notes: within a group price list (Organisation chart and management interview notes)
FunctionsWho markets and sells to customers?NoneHighInterview notes (Organisation chart and management interview notes)
AssetsWho holds the stock?NoneHighInterview notes: three weeks of sales (Organisation chart and management interview notes)
RisksWho bears inventory risk?LowHighSupply agreement clause 7.1 (Supply agreement — Foods Hellas to Distribution)
RisksWho bears market risk in the territory?LowHighSupply agreement clause 7.1 (Supply agreement — Foods Hellas to Distribution)
RisksWho bears product liability?HighLowInterview notes (Organisation chart and management interview notes)
FunctionsWho sets the distributor's margin?HighLowSupply agreement clause 2.1: prices set so that the distributor earns 3.5% (Supply agreement — Foods Hellas to Distribution)

Suggestion Drafted narrative. It counts for nothing until the item is confirmed.

Meridian Orchard Foods Hellas S.A. bears product liability; and sets the distributor's margin.

Meridian Orchard Distribution Ltd sets selling prices in the territory; markets and sells to customers; holds the stock; bears inventory risk; and bears market risk in the territory.

Of the 7 points, Foods Hellas S.A. leads on 2 and Distribution Ltd on 5.

Suggested characterisation: Meridian Orchard Distribution Ltd as a distributor bearing inventory risk and market risk in the territory on paper, but priced to a target margin set by Meridian Orchard Foods Hellas S.A. — which in substance points to a limited-risk distributor: a characterisation question for the team.

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Brand licence

Meridian Orchard Brands S.à r.l. → Meridian Orchard Distribution Ltd · €410,000

AreaQuestionBrands S.à r.l.Distribution LtdSource
FunctionsWho develops and protects the brands?HighLowGroup transfer pricing policy §5
AssetsWho legally owns the brands?HighNoneGroup transfer pricing policy §5
RisksWho bears the risk of the brands losing value?HighLowGroup transfer pricing policy §5

Suggestion Drafted narrative. It counts for nothing until the item is confirmed.

Meridian Orchard Brands S.à r.l. develops and protects the brands; legally owns the brands; and bears the risk of the brands losing value.

Of the 3 points, Brands S.à r.l. leads on 3 and Distribution Ltd on 0.

Suggested characterisation: Meridian Orchard Brands S.à r.l. as the owner and licensor of the intangible.

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Evidence still outstanding: Brand licence agreement (Luxembourg), due 2 Nov 2026 — 5 days overdue.

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

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