Engagements › Meridian Orchard Group › Local File
Local File
Assembled section by section for each entity that owes one. Each section shows what it rests on and where it stands. Content follows OECD Ch. V, Annexes I–II.
Shared Services LtdTreasury LtdDistribution Ltd
1. The local entity
DraftMeridian Orchard Distribution Ltd is a company resident in Cyprus. Distribution of juices and preserves in Cyprus and the region.
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: goods of €6,300,000 exceeds the €750,000 threshold.
Sources: ITL s.33(7)–(8); ITL s.33(9)(α); OECD Ch. V, Annexes I–II. Rests on: Obligations: Meridian Orchard Distribution Ltd (reviewed).
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ReviewedVerifiedConfirmedRests on, not yet confirmed: Obligations: Meridian Orchard Distribution Ltd.
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2. Purchase of juices and preserves
DraftPurchase of juices and preserves: Meridian Orchard Foods Hellas S.A. to Meridian Orchard Distribution Ltd, €6,300,000 in the year.
Method: Transactional net margin method, operating margin. Tested party: Meridian Orchard Distribution Ltd.
Interquartile range on 9 accepted comparables (inclusive quartiles): 2.49% to 3.19%, median 2.72%. Result of the tested party: 2.20%, below the range.
Written agreement: Supply agreement — Foods Hellas to Distribution; checked against the file (1 point(s) differ).
Risk allocation: Distributor bears inventory and market risk.
Sources: OECD 3.57; OECD 1.36. Rests on: Benchmarking: Purchase of juices and preserves (draft), Agreement: Purchase of juices and preserves (draft).
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ReviewedVerifiedConfirmedRests on, not yet confirmed: Benchmarking: Purchase of juices and preserves, Agreement: Purchase of juices and preserves.
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2. Brand licence
DraftBrand licence: Meridian Orchard Brands S.à r.l. to Meridian Orchard Distribution Ltd, €410,000 in the year.
Method: Comparable uncontrolled price, royalty rate. Tested party: Meridian Orchard Distribution Ltd.
No written agreement on file.
Risk allocation: Licensor bears brand development risk.
Sources: OECD 3.57; OECD 1.36.
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3. Financial information
DraftFinancial 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 Ch. V, Annexes I–II.
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