Engagements › Meridian Orchard Group › Year-End True-Ups
Year-End True-Ups
Each tested party against its contract and the range: whether an adjustment is suggested, how much, and how it is booked. The suggestion is always to the contract, never below it. The 2025 books are closed, so an adjustment for 2025 goes into the return; for 2026, the same check before 31 December lets an invoice or credit note fix it — to be confirmed by the practice.
Before the books close: each tested party against its target, with the invoice and journal.
2026, In The Year — while an invoice can still fix it
| Transaction | So Far | Range (2025) | Contract | Before 31 December |
|---|---|---|---|---|
| Shared services to Germany Management accounts to 30 September 2026 (invented) | 5.10% | 5.84% to 7.54% | 8.00% | €52,780 up Suggestion Invoice from Meridian Orchard Shared Services Ltd, €52,780 to the contract, 8.00%, on a forecast base of €1,820,000. To the contract, 8.00%: above the range — the counterparty's tax authority may disallow the excess; the policy is to review (suggestion). The defensive minimum: €13,442 to the low edge of the range, 5.84%. Beside the contract (8.00%: €52,780 up), for comparison: to the median, 7.43%: €42,384 up. Tax effect: at the Cyprus rate, to be confirmed by the practice. |
| Purchase of juices and preserves Management accounts to 30 September 2026 (invented) | 3.10% | 2.49% to 3.19% | 3.50% | On course In the range; €38,400 short of the agreement's 3.50% on a forecast base of €9,600,000 — invoice to the contract, or amend the agreement: for the practice to decide (OECD 1.42) |
Against last year's range until this year's study is refreshed; the forecast base and the year-to-date result come from the client's management accounts. The written agreement is the starting point (OECD 1.42).
Amounts are computed on unrounded margins; the percentages shown are rounded to two decimals, so a figure may differ slightly from one worked out from them.
2025, The Year Closed
Shared services to Germany
No adjustment suggested| Working | Value | Source |
|---|---|---|
| Tested party | Meridian Orchard Shared Services Ltd | |
| Target in the agreement or policy | 8.00% | |
| Earned | 6.40% | |
| The range | 5.84% to 7.54% | The target itself is outside it |
| Base | €1,729,323 | the cost base implied by the amount and the margin earned |
6.40% is within the range, so no transfer pricing adjustment is required (OECD 3.57, 3.60; suggestion); but the agreement says 8.00% and the provider has invoiced €27,669 less than its own contract — invoice to the contract, or amend the agreement to the range: for the practice to decide. The written agreement is the starting point (OECD 1.42).
Shared services to Greece
No adjustment suggested| Working | Value | Source |
|---|---|---|
| Tested party | Meridian Orchard Shared Services Ltd | |
| Target in the agreement or policy | 8.00% | |
| Earned | 6.40% | |
| The range | 5.84% to 7.54% | The target itself is outside it |
| Base | €864,662 | the cost base implied by the amount and the margin earned |
6.40% is within the range, so no transfer pricing adjustment is required (OECD 3.57, 3.60; suggestion); but the agreement says 8.00% and the provider has invoiced €13,835 less than its own contract — invoice to the contract, or amend the agreement to the range: for the practice to decide. The written agreement is the starting point (OECD 1.42).
Purchase of juices and preserves
€118,300 up| Working | Value | Source |
|---|---|---|
| Tested party | Meridian Orchard Distribution Ltd | |
| Target in the agreement or policy | 3.50% | |
| Earned | 2.20% | |
| The range | 2.49% to 3.19% | The target itself is outside it |
| Base | €9,100,000 | Trial balance: sales of Distribution Ltd (Trial balances FY2025, Cyprus entities) |
(contract − earned) × base: to the contract, never below it. The adjustment is €118,300 upwards for Meridian Orchard Distribution Ltd, to 3.50% (suggestion).
To the contract, 3.50%: above the range — the counterparty's tax authority may disallow the excess; the policy is to review (suggestion).
Beside the contract (3.50%: €118,300 up), for comparison: to the median, 2.72%: €47,234 up; to the nearest quartile, 2.49%: €26,079 up. Tax effect: at the Cyprus rate, to be confirmed by the practice.
Draft In the 2025 return of Meridian Orchard Distribution Ltd: a transfer pricing adjustment increasing its taxable profit by €118,300. How an adjustment for a closed year is made in Cyprus is to be confirmed by the practice.
VAT, customs value and withholding on an adjustment are for the team to check. For 2026, the same check before 31 December lets a credit note from Meridian Orchard Foods Hellas S.A. fix it in the books.
Amounts are computed on unrounded margins; the percentages shown are rounded to two decimals, so a figure may differ slightly from one worked out from them.
Priced By A Rate, No Study
- Brand licence: €410,000. No study — rate to be evidenced Licence-agreement search not yet run.
No true-up is drafted without a study: a rate alone does not show what is arm's length.