# Local File: Meridian Orchard Shared Services Ltd
Financial year 2025. Prepared with tp.alp for Meridian Orchard Group.

> **DRAFT — NOT SIGNED OFF.** 4 of 4 sections are not confirmed. Not for filing.

## 1. The local entity
Meridian Orchard Shared Services Ltd is a company resident in Cyprus. Finance, IT and HR support to group companies.
Group: Meridian Orchard Group. Entities in the group: Meridian Orchard Holdings Ltd (CY); Meridian Orchard Shared Services Ltd (CY); Meridian Orchard Treasury Ltd (CY); Meridian Orchard Distribution Ltd (CY); Meridian Orchard Trading GmbH (DE); Meridian Orchard Foods Hellas S.A. (GR); Meridian Orchard Brands S.à r.l. (LU).
Documentation duty: services of €2,760,000 exceeds the €750,000 threshold.

_Sources: Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(9)(α); OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash ddf7d6dace3ef495f711f5f816460f2b712cd1e0865418bcbf3ec0106811e758._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2. Shared services to Germany
Shared services to Germany: Meridian Orchard Shared Services Ltd to Meridian Orchard Trading GmbH, €1,840,000 in the year.
Method: Transactional net margin method, net cost plus. Tested party: Meridian Orchard Shared Services Ltd.
Interquartile range on 10 accepted comparables (inclusive quartiles): 5.48% to 9.11%, median 7.45%. Result of the tested party: 6.40%, within the range.
Written agreement: Shared services agreement — Trading GmbH; checked against the file (1 point(s) differ).
Risk allocation: Recipient bears the commercial risk of the services it orders.

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 3.57 (and 3.60–3.62); OECD Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash e3eff3ccc8d718860defb5888ed437f0269fe4ea3eb9baac06acb8ee00cf1cdb._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2. Shared services to Greece
Shared services to Greece: Meridian Orchard Shared Services Ltd to Meridian Orchard Foods Hellas S.A., €920,000 in the year.
Method: Transactional net margin method, net cost plus. Tested party: Meridian Orchard Shared Services Ltd.
Interquartile range on 10 accepted comparables (inclusive quartiles): 5.48% to 9.11%, median 7.45%. Result of the tested party: 6.40%, within the range.
Written agreement: Shared services agreement — Foods Hellas; checked against the file (0 point(s) differ).
Risk allocation: Recipient bears the commercial risk of the services it orders.

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 3.57 (and 3.60–3.62); OECD Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash 73c3e8f5a0cc0c6f52fb0c88685030dfcf7ab9f5307540083951598dc480fb2b._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
Financial information used in the analysis: Trial balances FY, Cyprus entities (SHA-256 1b08246b7a70eb66…).
Net cost plus earned on intra-group services: 6.40%.

_Sources: OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash 15354bb2e66cafa6548821f74c36c1830ddf24add78cc8bdab56e0a6da2c1235._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet