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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

DRAFT — not signed off. 4 of 4 sections are not yet confirmed; an export now carries the draft mark. Export Draft Export As Final

1. The local entity

Draft

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: ITL s.33(7)–(8); ITL s.33(9)(α); OECD Ch. V, Annexes I–II. Rests on: Obligations: Meridian Orchard Shared Services Ltd (verified).

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2. Shared services to Germany

Draft

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 3.57; OECD 1.36. Rests on: Benchmarking: Shared services to Germany (draft), Agreement: Shared services to Germany (reviewed).

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2. Shared services to Greece

Draft

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 3.57; OECD 1.36. Rests on: Benchmarking: Shared services to Germany (draft), Agreement: Shared services to Greece (verified).

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3. Financial information

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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 Ch. V, Annexes I–II.

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