Engagements › Northbridge Marine Holdings › Financing
Financing
The interest charged on each intra-group loan against the practice's yield analysis, with the working shown, and against the Tax Department's safe harbours where they apply.
Loans against the yield analysis and the Tax Department's safe harbours.
Interest-free shareholder balance
Northbridge Marine Holdings Ltd lends to Northbridge Bulk Carriers Ltd.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €3,200,000 | Balance sheet of Bulk Carriers Ltd, maximum in the year (invented) |
| Rate charged | — | |
| Term | — | |
| Interest in the year | €0 | Management accounts, Cyprus companies |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
An interest-free balance: left out for the company that owes it for 2022–2026 Tax Dept FAQ Q25. For the lender it counts; whether arm's length interest is to be imputed is for the practice — to be confirmed by the practice.
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Evidence still outstanding: Cash pool agreement and monthly balances, due 16 Nov 2026 — in 9 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hash4981689cd12e · a change to it reopens every sign-offPhysical cash pool: deposits from the tankers
Northbridge Tankers Ltd deposits its cash with Northbridge Marine Holdings Ltd.
| Working | Value | Source |
|---|---|---|
| Maximum principal | €6,800,000 | Cash pool statement, maximum balance in the year (invented); measured like a loan by analogy to FAQ question 10 |
| Deposit rate paid | 3.50% | Per the client (cash pool agreement requested, not yet on file): deposit rate paid by the pool leader (invented) |
| Term | — | |
| Interest in the year | €238,000 | Per the client (cash pool agreement requested, not yet on file): interest paid on the deposits in the year (invented) |
No independent yield analysis is on file for this loan: it is tested against the safe harbour below, where one applies.
Tax Department safe harbours Circular 6/2023
Not available to Northbridge Marine Holdings Ltd: the safe harbour rates apply only where its financial transactions stay under the published threshold, measured by the maximum principal — here financing €10,000,000 (Tax Dept FAQ Q31, Tax Dept FAQ Q9–10).
For comparison only, had it applied — Δ.3, the Cyprus company borrows Circular 6/2023 ¶25: the CY 10-year government bond yield for December 2024 2.81% plus 1.50% = a cap of 4.31%, against 3.50% paid — within the cap. Source: ECB, IRS/M.CY.L.L40.CI.0000.EUR.N.Z — a monthly average standing in for the yield the Tax Department publishes for the notional interest deduction at 31 December (Tax Dept FAQ Q26; Circular 6/2023 ¶21) — to be confirmed by the practice.
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Cash pool agreement and monthly balances, due 16 Nov 2026 — in 9 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hashed004eb6e3a7 · a change to it reopens every sign-off