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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. 3 of 3 sections are not yet confirmed; an export now carries the draft mark. Export Draft Export As Final

1. The local entity

Draft

Meridian 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

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Intra-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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Rests on, not yet confirmed: Financing: Intra-group loan to Germany, Agreement: Intra-group loan to Germany.

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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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