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 Treasury Ltd is a company resident in Cyprus. Group financing and cash management.
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: financing of €882,000 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 Treasury Ltd (confirmed).
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2. Intra-group loan to Germany
DraftIntra-group loan to Germany: Meridian Orchard Treasury Ltd to Meridian Orchard Trading GmbH, €882,000 in the year.
Method: Comparable uncontrolled price, interest rate. Tested party: Meridian Orchard Treasury Ltd.
Yield analysis, interquartile: 4.30% to 5.10%, median 4.65%. Rate charged: 4.90%, within the range.
Written agreement: Loan agreement — Trading GmbH; checked against the file (1 point(s) differ).
Risk allocation: Borrower bears credit risk; lender bears funding risk.
Sources: OECD 3.57; OECD 1.36; Circulars 6/2023, 5/2026 · to be confirmed by the practice. Rests on: Financing: Intra-group loan to Germany (reviewed), Agreement: Intra-group loan to Germany (draft).
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ReviewedVerifiedConfirmedRests on, not yet confirmed: Financing: Intra-group loan to Germany, Agreement: Intra-group loan to Germany.
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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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