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
| Area | Question | Shared Services Ltd | Trading GmbH | Source |
|---|---|---|---|---|
| Functions | Who decides what services are ordered? | Low | High | Interview notes (Organisation chart and management interview notes) |
| Functions | Who decides how the services are delivered? | High | Low | Interview notes (Organisation chart and management interview notes) |
| Functions | Who employs the people who perform them? | High | None | Interview notes: 31 staff in Limassol (Organisation chart and management interview notes) |
| Assets | Who owns the systems and licences used? | Medium | Low | Interview notes (Organisation chart and management interview notes) |
| Risks | Who bears the risk that the services are not needed? | Low | High | Services agreement clause 5.2 |
| Risks | Who bears the risk of the services being performed badly? | Medium | Low | Services 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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Content hashd90e43a5428a · a change to it reopens every sign-offShared services to Greece
Meridian Orchard Shared Services Ltd → Meridian Orchard Foods Hellas S.A. · €920,000
| Area | Question | Shared Services Ltd | Foods Hellas S.A. | Source |
|---|---|---|---|---|
| Functions | Who decides what services are ordered? | Low | High | Interview notes (Organisation chart and management interview notes) |
| Functions | Who decides how the services are delivered? | High | Low | Interview notes (Organisation chart and management interview notes) |
| Functions | Who employs the people who perform them? | High | None | Interview notes: 31 staff in Limassol (Organisation chart and management interview notes) |
| Assets | Who owns the systems and licences used? | Medium | Low | Interview notes (Organisation chart and management interview notes) |
| Risks | Who bears the risk that the services are not needed? | Low | High | Services agreement clause 5.2 |
| Risks | Who bears the risk of the services being performed badly? | Medium | Low | Services 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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Content hash891d7087c57a · a change to it reopens every sign-offIntra-group loan to Germany
Meridian Orchard Treasury Ltd → Meridian Orchard Trading GmbH · €882,000
| Area | Question | Treasury Ltd | Trading GmbH | Source |
|---|---|---|---|---|
| Functions | Who decides to lend, and on what terms? | High | Low | Group transfer pricing policy §3 |
| Functions | Who monitors the borrower and the loan? | Medium | None | Interview notes (Organisation chart and management interview notes) |
| Assets | Who provides the capital? | High | None | Loan agreement clause 2.1 (Loan agreement — Trading GmbH) |
| Risks | Who bears the credit risk? | High | None | Loan agreement clause 6.1 (Loan agreement — Trading GmbH) |
| Risks | Who bears the interest-rate risk on a fixed rate? | Medium | Low | Loan 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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ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
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.
Hash
Content hashffd1d140504c · a change to it reopens every sign-offPurchase of juices and preserves
Meridian Orchard Foods Hellas S.A. → Meridian Orchard Distribution Ltd · €6,300,000
| Area | Question | Foods Hellas S.A. | Distribution Ltd | Source |
|---|---|---|---|---|
| Functions | Who sets selling prices in the territory? | None | Medium | Interview notes: within a group price list (Organisation chart and management interview notes) |
| Functions | Who markets and sells to customers? | None | High | Interview notes (Organisation chart and management interview notes) |
| Assets | Who holds the stock? | None | High | Interview notes: three weeks of sales (Organisation chart and management interview notes) |
| Risks | Who bears inventory risk? | Low | High | Supply agreement clause 7.1 (Supply agreement — Foods Hellas to Distribution) |
| Risks | Who bears market risk in the territory? | Low | High | Supply agreement clause 7.1 (Supply agreement — Foods Hellas to Distribution) |
| Risks | Who bears product liability? | High | Low | Interview notes (Organisation chart and management interview notes) |
| Functions | Who sets the distributor's margin? | High | Low | Supply 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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Hash
Content hash38f0f1e4b29c · a change to it reopens every sign-offBrand licence
Meridian Orchard Brands S.à r.l. → Meridian Orchard Distribution Ltd · €410,000
| Area | Question | Brands S.à r.l. | Distribution Ltd | Source |
|---|---|---|---|---|
| Functions | Who develops and protects the brands? | High | Low | Group transfer pricing policy §5 |
| Assets | Who legally owns the brands? | High | None | Group transfer pricing policy §5 |
| Risks | Who bears the risk of the brands losing value? | High | Low | Group 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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ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
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.
Hash
Content hash45ae39c8ea01 · a change to it reopens every sign-off