{"engagement":"Meridian Orchard Group","financialYear":2025,"complete":false,"documents":[{"id":"d-policy","name":"Group transfer pricing policy","source":"Provided by the group finance director","sha256":"6b4e1e85c558e9bff699eaa1cfbfdda685444c67459ff79c0783c46761796864","intact":true},{"id":"d-sa-de","name":"Shared services agreement — Trading GmbH","source":"Signed copy, uploaded by the client","sha256":"6453ef805e02c38e7dbe3deed965ce677f7b3227a8dc48b3b68d758283e77176","intact":true},{"id":"d-sa-gr","name":"Shared services agreement — Foods Hellas","source":"Signed copy, uploaded by the client","sha256":"14905b835dc024489b3a7468a1aafcbcd442a3ab69ed39dbcb0493324c937f1f","intact":true},{"id":"d-loan","name":"Loan agreement — Trading GmbH","source":"Signed copy, uploaded by the client","sha256":"09cfb81028f1a13c3de9f5eb87bb2f39b177314d61f709855a16947fc7b6d7cc","intact":true},{"id":"d-sup","name":"Supply agreement — Foods Hellas to Distribution","source":"Signed copy, uploaded by the client","sha256":"fb2ac2c5d5ced86d4bc5a98012a5b65e57a81cea202f88bb0582aba388017743","intact":true},{"id":"d-org","name":"Organisation chart and management interview notes","source":"Interview with the group CFO, notes by the team","sha256":"d618b6a9bc396fb9bd8cf085786b2f6e23e5562e02c0c14efd435d8a1e9f1ce2","intact":true},{"id":"d-tb","name":"Trial balances FY, Cyprus entities","source":"Group accounting system extract, uploaded by the client","sha256":"1b08246b7a70eb6672f18c51fd77ebd941d7e7419d934c8ecbc500b13faa8063","intact":true},{"id":"d-yield","name":"Credit standing and yield analysis, Trading GmbH","source":"Prepared by the team from an invented rating model and invented bond data","sha256":"b8a234cf20a771e68ae43f6055590f86fc64458f7cad82f4fb50c4f875c799da","intact":true}],"items":[{"id":"obl:e-hold","title":"Obligations: Meridian Orchard Holdings Ltd","state":"draft","contentHash":"697d2bee866cb5287f8b1bd1d7d6187b0639970bbeedb735d1ead3439b5f6aab","content":{"fy":2025,"entity":"e-hold","rules":[["cy.lf.threshold","verified",750000],["cy.lf.threshold.circ2024","tbc",1000000],["cy.lf.threshold.circ2024.fin","tbc",5000000]],"lines":[],"localFile":false,"summaryTable":false},"rests_on":[],"signoffs":[],"changes":[]},{"id":"obl:e-ss","title":"Obligations: Meridian Orchard Shared Services Ltd","state":"verified","contentHash":"152219608bff9edde76c2b23c03bd7db4664e8e7b8c25e31f4c681506b3c3ae5","content":{"fy":2025,"entity":"e-ss","rules":[["cy.lf.threshold","verified",750000],["cy.lf.threshold.circ2024","tbc",1000000],["cy.lf.threshold.circ2024.fin","tbc",5000000]],"lines":[["services",2760000,true,true]],"localFile":true,"summaryTable":true},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Dimitri Wells","at":"28 Oct 2026 14:00","looked_at":"Transaction totals against the trial balance (doc d-tb); the threshold rule cy.lf.threshold, Law 101(I)/2022 s.33(9)(α).","note":"Services total agrees to the ledger.","change_reason":"","countsNow":true,"contentHash":"152219608bff9edde76c2b23c03bd7db4664e8e7b8c25e31f4c681506b3c3ae5"},{"stage":"verified","by":"Marina Costa","at":"30 Oct 2026 14:01","looked_at":"The category totals and the rule citations; the difference between the enacted threshold and the 2024 circular.","note":"Required on either basis. Noted for the partner.","change_reason":"","countsNow":true,"contentHash":"152219608bff9edde76c2b23c03bd7db4664e8e7b8c25e31f4c681506b3c3ae5"}],"changes":[]},{"id":"obl:e-tre","title":"Obligations: Meridian Orchard Treasury Ltd","state":"confirmed","contentHash":"84a486c7981f2e9e613f33e8293d49a9f9739efbc3f44921f810a0c004b70546","content":{"fy":2025,"entity":"e-tre","rules":[["cy.lf.threshold","verified",750000],["cy.lf.threshold.circ2024","tbc",1000000],["cy.lf.threshold.circ2024.fin","tbc",5000000]],"lines":[["loan",882000,true,false]],"localFile":true,"summaryTable":true},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Dimitri Wells","at":"28 Oct 2026 14:02","looked_at":"Loan interest against the interest statements; rule cy.lf.threshold.","note":"Financing total agrees.","change_reason":"","countsNow":true,"contentHash":"84a486c7981f2e9e613f33e8293d49a9f9739efbc3f44921f810a0c004b70546"},{"stage":"verified","by":"Marina Costa","at":"30 Oct 2026 14:03","looked_at":"Threshold basis; the €5,000,000 circular figure is marked to be confirmed.","note":"Required on the enacted threshold, not on the circular: the practice to settle which applies.","change_reason":"","countsNow":true,"contentHash":"84a486c7981f2e9e613f33e8293d49a9f9739efbc3f44921f810a0c004b70546"},{"stage":"confirmed","by":"Jane Doe","at":"1 Nov 2026 14:04","looked_at":"Both threshold bases and the open point on the circular.","note":"Proceed on the law as enacted; revisit when the circular is checked.","change_reason":"","countsNow":true,"contentHash":"84a486c7981f2e9e613f33e8293d49a9f9739efbc3f44921f810a0c004b70546"}],"changes":[]},{"id":"obl:e-dist","title":"Obligations: Meridian Orchard Distribution Ltd","state":"reviewed","contentHash":"67d5bb862f88cd66e1ec8089afb6c86531e5247e932fd41b6f66dccc7c6f2fb1","content":{"fy":2025,"entity":"e-dist","rules":[["cy.lf.threshold","verified",750000],["cy.lf.threshold.circ2024","tbc",1000000],["cy.lf.threshold.circ2024.fin","tbc",5000000]],"lines":[["goods",6300000,true,true],["royalty",410000,false,false]],"localFile":true,"summaryTable":true},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Niki Papas","at":"29 Oct 2026 14:05","looked_at":"Goods and royalty totals; the royalty is below the threshold.","note":"","change_reason":"","countsNow":true,"contentHash":"67d5bb862f88cd66e1ec8089afb6c86531e5247e932fd41b6f66dccc7c6f2fb1"}],"changes":[]},{"id":"bench:t1","title":"Benchmarking: Shared services to Germany","state":"draft","contentHash":"448748961cd510379e8916a4370cc4b5f10dc77ed0f83243412ba6e6b371ce75","content":{"fy":2025,"tx":["t1","Transactional net margin method, net cost plus",0.08,0.064],"indicator":"ncp","method":"inclusive","comps":[["t1-c01","accept","OK","Business description: \"Back-office finance and payroll support to businesses\"; independent; profitable in at least 2 of 3 years.",0.10024128],["t1-c02","accept","OK","Business description: \"Shared services: accounting and HR administration\"; independent; profitable in at least 2 of 3 years.",0.07466509],["t1-c03","accept","OK","Business description: \"IT helpdesk and infrastructure support services\"; independent; profitable in at least 2 of 3 years.",0.06556856],["t1-c04","reject","ONEOFF","Annual report notes a one-off restructuring that inflates year two; not representative.",0.05823482],["t1-c05","accept","OK","Business description: \"Group administration, treasury and reporting services\"; independent; profitable in at least 2 of 3 years.",0.0960954],["t1-c06","accept","OK","Business description: \"Shared service centre: accounts payable and receivable\"; independent; profitable in at least 2 of 3 years.",0.07428816],["t1-c07",null,null,null,0.0947811],["t1-c08","accept","OK","Business description: \"IT managed services for group companies\"; independent; profitable in at least 2 of 3 years.",0.10154313],["t1-c09","accept","OK","Business description: \"Business process outsourcing: finance and procurement\"; independent; profitable in at least 2 of 3 years.",0.05120277],["t1-c10","accept","OK","Business description: \"Finance and IT support to related companies\"; independent; profitable in at least 2 of 3 years.",0.0181158],["t1-c11","accept","OK","Business description: \"Administrative and accounting services\"; independent; profitable in at least 2 of 3 years.",0.03268577],["t1-c12","reject","FUNC","Business description: \"Develops and sells its own software product\" — contains \"software product\", which the search strategy excludes.",0.09026309],["t1-c13","reject","IND","Database field \"Independence indicator\": shareholder with more than 50% of the capital is a company in a larger group.",0.1011568],["t1-c14","reject","LOSS","Operating loss in 2 of the 3 years studied.",0.00651484],["t1-c15","reject","FUNC","Business description: \"Holding company with a small admin function\" — contains \"holding company\", which the search strategy excludes.",0.08013865],["t1-c16","accept","OK","Business description: \"Outsourced finance and reporting\"; independent; profitable in at least 2 of 3 years.",0.07613245]],"range":[10,0.05479422,0.07447662,0.09110466],"where":"within"},"rests_on":[],"signoffs":[],"changes":[{"by":"Niki Papas","at":"25 Oct 2026 12:00","what":"Decided the comparables against the screening suggestions","reason":"Search strategy applied; overrides explained per company."}]},{"id":"bench:t4","title":"Benchmarking: Purchase of juices and preserves","state":"draft","contentHash":"ce975843d81dafd84e4def0541546b1382243561d23af1ede9b6a24dc6f59c5e","content":{"fy":2025,"tx":["t4","Transactional net margin method, operating margin",0.035,0.022],"indicator":"om","method":"inclusive","comps":[["t4-c01","accept","OK","Business description: \"Wholesale distribution of beverages and preserves\"; independent; profitable in at least 2 of 3 years.",0.02699466],["t4-c02","accept","OK","Business description: \"Distribution of juices and packaged foods\"; independent; profitable in at least 2 of 3 years.",0.03002138],["t4-c03","accept","OK","Business description: \"Wholesale of non-alcoholic beverages\"; independent; profitable in at least 2 of 3 years.",0.03186273],["t4-c04","accept","OK","Business description: \"Wholesale distribution of preserved foods\"; independent; profitable in at least 2 of 3 years.",0.00494615],["t4-c05","accept","OK","Business description: \"Distribution of packaged food and drink\"; independent; profitable in at least 2 of 3 years.",0.01926872],["t4-c06",null,null,null,0.0234607],["t4-c07","accept","OK","Business description: \"Wholesale of food and soft drinks to retailers\"; independent; profitable in at least 2 of 3 years.",0.02719053],["t4-c08","reject","DATA","The second year's accounts are unconsolidated and not comparable with the other years.",0.02188948],["t4-c09","accept","OK","Business description: \"Imports and distributes jams and preserves\"; independent; profitable in at least 2 of 3 years.",0.02486578],["t4-c10","accept","OK","Business description: \"Wholesale of branded food and drink products\"; independent; profitable in at least 2 of 3 years.",0.04677008],["t4-c11","reject","IND","Database field \"Independence indicator\": shareholder with more than 50% of the capital is a company in a larger group.",0.02939523],["t4-c12","accept","OK","Business description: \"Wholesale of juices and preserves\"; independent; profitable in at least 2 of 3 years.",0.03578697],["t4-c13","reject","FUNC","Business description: \"Real estate and food wholesale\" — contains \"real estate\", which the search strategy excludes.",0.04402687],["t4-c14","reject","LOSS","Operating loss in 2 of the 3 years studied.",-0.00439223]],"range":[9,0.02486578,0.02719053,0.03186273],"where":"below"},"rests_on":[],"signoffs":[],"changes":[{"by":"Niki Papas","at":"25 Oct 2026 12:00","what":"Decided the comparables against the screening suggestions","reason":"Search strategy applied; overrides explained per company."}]},{"id":"fin:t3","title":"Financing: Intra-group loan to Germany","state":"reviewed","contentHash":"f407373273373c04722427a6fb4d6cfba0221e0113128118133d4def12e7aef0","content":{"tx":"t3","amount":882000,"principal":18000000,"rate":0.049,"yields":{"low":0.043,"mid":0.0465,"high":0.051},"where":"within","sources":{"principal":"Loan agreement clause 2.1 (doc d-loan)","rate":"Loan agreement clause 4.1 (doc d-loan)","tenor_years":"Loan agreement clause 3.1 (doc d-loan)","yield_high":"Yield analysis para 2 (doc d-yield)","yield_low":"Yield analysis para 2 (doc d-yield)","yield_mid":"Yield analysis para 2 (doc d-yield)"}},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Dimitri Wells","at":"3 Nov 2026 14:09","looked_at":"Loan agreement clauses 2.1, 3.1, 4.1; yield analysis (doc d-yield) para 2.","note":"Rate within the interquartile yields.","change_reason":"","countsNow":true,"contentHash":"f407373273373c04722427a6fb4d6cfba0221e0113128118133d4def12e7aef0"}],"changes":[{"by":"Niki Papas","at":"27 Oct 2026 12:00","what":"Entered the loan terms and yields","reason":"From the loan agreement and the yield analysis, each with its source."}]},{"id":"agr:a1","title":"Agreement: Shared services to Germany","state":"reviewed","contentHash":"0b4629d84188c8703238e781acf1d5276cb9e01daf0c3af6109a3d447f0e1853","content":{"doc":["d-sa-de","6453ef805e02c38e7dbe3deed965ce677f7b3227a8dc48b3b68d758283e77176"],"checks":[["provider","Meridian Orchard Shared Services Ltd","Meridian Orchard Shared Services Ltd","match"],["recipient","Meridian Orchard Trading GmbH","Meridian Orchard Trading GmbH","match"],["margin","8.00%","8.00%","match"],["payment_days","60 days","30 days","mismatch"],["risk","Recipient bears the commercial risk of the services it orders","Recipient bears the commercial risk of the services it orders","match"]]},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Niki Papas","at":"31 Oct 2026 14:06","looked_at":"Agreement clauses 3.1, 3.4 and 5.2 against the policy; payment terms differ (60 against 30 days).","note":"Flagged: the client to confirm which payment term applies.","change_reason":"","countsNow":true,"contentHash":"0b4629d84188c8703238e781acf1d5276cb9e01daf0c3af6109a3d447f0e1853"}],"changes":[]},{"id":"agr:a2","title":"Agreement: Shared services to Greece","state":"verified","contentHash":"051275c81d1bd980ed3de7617d6618bddb3a33376b2c081061a0c49dc5183c2f","content":{"doc":["d-sa-gr","14905b835dc024489b3a7468a1aafcbcd442a3ab69ed39dbcb0493324c937f1f"],"checks":[["provider","Meridian Orchard Shared Services Ltd","Meridian Orchard Shared Services Ltd","match"],["recipient","Meridian Orchard Foods Hellas S.A.","Meridian Orchard Foods Hellas S.A.","match"],["margin","8.00%","8.00%","match"],["payment_days","30 days","30 days","match"],["risk","Recipient bears the commercial risk of the services it orders","Recipient bears the commercial risk of the services it orders","match"]]},"rests_on":[],"signoffs":[{"stage":"reviewed","by":"Niki Papas","at":"31 Oct 2026 14:07","looked_at":"Agreement against the policy: all points agree.","note":"","change_reason":"","countsNow":true,"contentHash":"051275c81d1bd980ed3de7617d6618bddb3a33376b2c081061a0c49dc5183c2f"},{"stage":"verified","by":"Marina Costa","at":"2 Nov 2026 14:08","looked_at":"Clauses 3.1, 3.4, 5.2.","note":"","change_reason":"","countsNow":true,"contentHash":"051275c81d1bd980ed3de7617d6618bddb3a33376b2c081061a0c49dc5183c2f"}],"changes":[]},{"id":"agr:a3","title":"Agreement: Intra-group loan to Germany","state":"draft","contentHash":"172c5a629b601a18fc63850ed7740858914fed4e159efbfb8efe4aca9ea0b596","content":{"doc":["d-loan","09cfb81028f1a13c3de9f5eb87bb2f39b177314d61f709855a16947fc7b6d7cc"],"checks":[["provider","Meridian Orchard Treasury Ltd","Meridian Orchard Treasury Ltd","match"],["recipient","Meridian Orchard Trading GmbH","Meridian Orchard Trading GmbH","match"],["rate","4.90%","4.90%","match"],["payment_days","—","90 days","missing"],["risk","Borrower bears credit risk; lender bears funding risk","Borrower bears credit risk; lender bears funding risk","match"]]},"rests_on":[],"signoffs":[],"changes":[]},{"id":"agr:a4","title":"Agreement: Purchase of juices and preserves","state":"draft","contentHash":"b7787117dc15fafbf626b0baed804a2b8d506ae5870f468117a113f31e54cf6b","content":{"doc":["d-sup","fb2ac2c5d5ced86d4bc5a98012a5b65e57a81cea202f88bb0582aba388017743"],"checks":[["provider","Meridian Orchard Foods Hellas S.A.","Meridian Orchard Foods Hellas S.A.","match"],["recipient","Meridian Orchard Distribution Ltd","Meridian Orchard Distribution Ltd","match"],["margin","3.50%","3.50%","match"],["payment_days","45 days","45 days","match"],["risk","Distributor bears inventory risk and market risk","Distributor bears inventory and market risk","mismatch"]]},"rests_on":[],"signoffs":[],"changes":[]},{"id":"lf:e-ss:1","title":"Meridian Orchard Shared Services Ltd: 1. The local entity","state":"draft","contentHash":"ddf7d6dace3ef495f711f5f816460f2b712cd1e0865418bcbf3ec0106811e758","content":{"text":["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."],"cites":["cy.who","cy.lf.threshold","oecd.docs"],"hashes":[["obl:e-ss","152219608bff9edde76c2b23c03bd7db4664e8e7b8c25e31f4c681506b3c3ae5"]]},"rests_on":["obl:e-ss"],"signoffs":[],"changes":[]},{"id":"lf:e-ss:2:t1","title":"Meridian Orchard Shared Services Ltd: 2. Shared services to Germany","state":"draft","contentHash":"e3eff3ccc8d718860defb5888ed437f0269fe4ea3eb9baac06acb8ee00cf1cdb","content":{"text":["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."],"cites":["oecd.iqr","oecd.factors"],"hashes":[["bench:t1","448748961cd510379e8916a4370cc4b5f10dc77ed0f83243412ba6e6b371ce75"],["agr:a1","0b4629d84188c8703238e781acf1d5276cb9e01daf0c3af6109a3d447f0e1853"]]},"rests_on":["bench:t1","agr:a1"],"signoffs":[],"changes":[]},{"id":"lf:e-ss:2:t2","title":"Meridian Orchard Shared Services Ltd: 2. Shared services to Greece","state":"draft","contentHash":"73c3e8f5a0cc0c6f52fb0c88685030dfcf7ab9f5307540083951598dc480fb2b","content":{"text":["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."],"cites":["oecd.iqr","oecd.factors"],"hashes":[["bench:t1","448748961cd510379e8916a4370cc4b5f10dc77ed0f83243412ba6e6b371ce75"],["agr:a2","051275c81d1bd980ed3de7617d6618bddb3a33376b2c081061a0c49dc5183c2f"]]},"rests_on":["bench:t1","agr:a2"],"signoffs":[],"changes":[]},{"id":"lf:e-ss:3","title":"Meridian Orchard Shared Services Ltd: 3. Financial information","state":"draft","contentHash":"15354bb2e66cafa6548821f74c36c1830ddf24add78cc8bdab56e0a6da2c1235","content":{"text":["Financial information used in the analysis: Trial balances FY, Cyprus entities (SHA-256 1b08246b7a70eb66…).","Net cost plus earned on intra-group services: 6.40%."],"cites":["oecd.docs"],"hashes":[]},"rests_on":[],"signoffs":[],"changes":[]},{"id":"lf:e-tre:1","title":"Meridian Orchard Treasury Ltd: 1. The local entity","state":"draft","contentHash":"cbdf14d596663a34804e33c5e2b45a3faeaaf02489da3c59ac2a151144c79661","content":{"text":["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."],"cites":["cy.who","cy.lf.threshold","oecd.docs"],"hashes":[["obl:e-tre","84a486c7981f2e9e613f33e8293d49a9f9739efbc3f44921f810a0c004b70546"]]},"rests_on":["obl:e-tre"],"signoffs":[],"changes":[]},{"id":"lf:e-tre:2:t3","title":"Meridian Orchard Treasury Ltd: 2. Intra-group loan to Germany","state":"draft","contentHash":"26b1e4d5658db2a28990857e462095f3994fb257ddc87a853334ef641d2cf9ac","content":{"text":["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."],"cites":["oecd.iqr","oecd.factors","cy.fin"],"hashes":[["fin:t3","f407373273373c04722427a6fb4d6cfba0221e0113128118133d4def12e7aef0"],["agr:a3","172c5a629b601a18fc63850ed7740858914fed4e159efbfb8efe4aca9ea0b596"]]},"rests_on":["fin:t3","agr:a3"],"signoffs":[],"changes":[]},{"id":"lf:e-tre:3","title":"Meridian Orchard Treasury Ltd: 3. Financial information","state":"draft","contentHash":"15354bb2e66cafa6548821f74c36c1830ddf24add78cc8bdab56e0a6da2c1235","content":{"text":["Financial information used in the analysis: Trial balances FY, Cyprus entities (SHA-256 1b08246b7a70eb66…).","Net cost plus earned on intra-group services: 6.40%."],"cites":["oecd.docs"],"hashes":[]},"rests_on":[],"signoffs":[],"changes":[]},{"id":"lf:e-dist:1","title":"Meridian Orchard Distribution Ltd: 1. The local entity","state":"draft","contentHash":"ccd61351661e0093b99dd0713e57669dbd97583b26d78abe690e58d50efbfb69","content":{"text":["Meridian 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."],"cites":["cy.who","cy.lf.threshold","oecd.docs"],"hashes":[["obl:e-dist","67d5bb862f88cd66e1ec8089afb6c86531e5247e932fd41b6f66dccc7c6f2fb1"]]},"rests_on":["obl:e-dist"],"signoffs":[],"changes":[]},{"id":"lf:e-dist:2:t4","title":"Meridian Orchard Distribution Ltd: 2. Purchase of juices and preserves","state":"draft","contentHash":"a9a158b883540920a6d49e3c0aab12f69a7e2c8d15369eb5d7e9a60b18c76bfa","content":{"text":["Purchase 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."],"cites":["oecd.iqr","oecd.factors"],"hashes":[["bench:t4","ce975843d81dafd84e4def0541546b1382243561d23af1ede9b6a24dc6f59c5e"],["agr:a4","b7787117dc15fafbf626b0baed804a2b8d506ae5870f468117a113f31e54cf6b"]]},"rests_on":["bench:t4","agr:a4"],"signoffs":[],"changes":[]},{"id":"lf:e-dist:2:t5","title":"Meridian Orchard Distribution Ltd: 2. Brand licence","state":"draft","contentHash":"b146624080a3352076d491c36ee51211cca206d9ef2c95532ab6bbd1a8ec9e99","content":{"text":["Brand 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."],"cites":["oecd.iqr","oecd.factors"],"hashes":[]},"rests_on":[],"signoffs":[],"changes":[]},{"id":"lf:e-dist:3","title":"Meridian Orchard Distribution Ltd: 3. Financial information","state":"draft","contentHash":"15354bb2e66cafa6548821f74c36c1830ddf24add78cc8bdab56e0a6da2c1235","content":{"text":["Financial information used in the analysis: Trial balances FY, Cyprus entities (SHA-256 1b08246b7a70eb66…).","Net cost plus earned on intra-group services: 6.40%."],"cites":["oecd.docs"],"hashes":[]},"rests_on":[],"signoffs":[],"changes":[]}],"packHash":"118870ccfe5d59a0a93e72ea8a97fab26c1f9be3405b0e58fe91fcc577d0c28d"}