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Financing
The interest charged on an intra-group loan against the yield analysis, with the working shown. The Cyprus simplified approach is not applied: its circular was not read.
No safe-harbour margin is shown. Back-to-back and group financing rules are reported in Tax Department circulars (Circulars 6/2023, 5/2026 · to be confirmed by the practice) and the figures are to be confirmed by the practice. Until the practice has read them, the calculator compares the rate charged with the practice's own yield analysis, whose figures were entered with their source.
Intra-group loan to Germany
Meridian Orchard Treasury Ltd lends to Meridian Orchard Trading GmbH.
| Working | Value | Source |
|---|---|---|
| Principal | €18,000,000 | Loan agreement clause 2.1 (doc d-loan) |
| Rate charged | 4.90% | Loan agreement clause 4.1 (doc d-loan) |
| Term | 5 years | Loan agreement clause 3.1 (doc d-loan) |
| Interest charged in the year | €882,000 | Interest statements |
| Yield analysis, lower quartile | 4.30% | Yield analysis para 2 (doc d-yield) |
| Yield analysis, median | 4.65% | Yield analysis para 2 (doc d-yield) |
| Yield analysis, upper quartile | 5.10% | Yield analysis para 2 (doc d-yield) |
| Interest at the median yield | €837,000.00 | Principal × median yield |
| Charged less interest at the median | €45,000.00 | Difference |
The rate charged is within the interquartile yields.
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ReviewedVerifiedConfirmed- Reviewed by Dimitri Wells, 3 Nov 2026 14:09 · looked at: Loan agreement clauses 2.1, 3.1, 4.1; yield analysis (doc d-yield) para 2. — Rate within the interquartile yields.
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