tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Engagements › Northbridge Marine Holdings › 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.

Assembled section by section; exports as final only when confirmed.

Northbridge Marine Holdings LtdNorthbridge Crew Services Ltd

DRAFT — not signed off. 4 of 4 sections are not yet confirmed; an export now carries the draft mark. Export Draft On iPad: Print → Save as PDF for a readable copy. Export As Final — export as final once all 4 sections are confirmed, 4 to go

1. The local entity

Draft

Northbridge Marine Holdings Ltd is a company resident in Cyprus. Holding company and leader of the group's physical cash pool.

Group: Northbridge Marine Holdings. Entities in the group: Northbridge Marine Holdings Ltd (CY); Northbridge Ship Management Ltd (CY); Northbridge Bulk Carriers Ltd (CY); Northbridge Crew Services Ltd (CY); Northbridge Tankers Ltd (MT).

Documentation duty: financing, by its maximum principal, of €10,000,000 exceeds the €5,000,000 threshold the Tax Department publishes.

Sources: ITL s.33(7)–(8); Tax Dept FAQ Q52; Tax Dept FAQ Q9–10; OECD Ch. V, Annexes I–II. Rests on: Obligations: Northbridge Marine Holdings Ltd (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Obligations: Northbridge Marine Holdings Ltd.

Next: 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.

HashContent hash dea9aa15dab5 · a change to it reopens every sign-off

2.1 Interest-free shareholder balance

Draft

Interest-free shareholder balance: Northbridge Marine Holdings Ltd to Northbridge Bulk Carriers Ltd, interest €0 in the year on a maximum principal of €3,200,000.

Method: None charged: an interest-free balance. Tested party: Northbridge Marine Holdings Ltd.

Circular 6/2023 safe harbour: not available: the category is over the threshold.

No written agreement on file.

Risk allocation: Holding company bears the credit risk.

Sources: OECD 1.36; Tax Dept FAQ Q31. Rests on: Financing: Interest-free shareholder balance (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Interest-free shareholder balance.

Next: 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.

HashContent hash 90e6362455c2 · a change to it reopens every sign-off

2.2 Physical cash pool: deposits from the tankers

Draft

Physical cash pool: deposits from the tankers: Northbridge Tankers Ltd to Northbridge Marine Holdings Ltd, interest €238,000 in the year on a maximum principal of €6,800,000.

Method: Comparable uncontrolled price, deposit rate. Tested party: Northbridge Marine Holdings Ltd.

Circular 6/2023 safe harbour: not available: the category is over the threshold.

No written agreement on file.

Risk allocation: The depositor bears the credit risk of the pool leader.

Sources: OECD 1.36; Tax Dept FAQ Q31. Rests on: Financing: Physical cash pool: deposits from the tankers (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Physical cash pool: deposits from the tankers.

Next: 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.

HashContent hash cc7840b403b2 · a change to it reopens every sign-off

3. Financial information

Draft

Financial information used in the analysis: Management accounts, Cyprus companies (SHA-256 58754b9bee6f52c4…).

Interest-free shareholder balance: maximum principal €3,200,000; rate none charged (interest-free); tenor not on file; interest in the year €0.

Physical cash pool: deposits from the tankers: maximum principal €6,800,000; rate 3.50%; tenor not on file; interest in the year €238,000.

Sources: OECD Ch. V, Annexes I–II; Tax Dept FAQ Q9–10.

Sign-Off

ReviewedVerifiedConfirmed

Next: 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.

HashContent hash 0f941d762c5c · a change to it reopens every sign-off