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

Engagements › Pinewood Street Pharma › 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.

Loan to the Greek distributor

Pinewood Street Finance Ltd lends to Pinewood Street Hellas S.A.

WorkingValueSource
Maximum principal€3,000,000Loan agreement clause 2 (invented)
Rate charged3.20%Loan agreement clause 4 (invented)
Term—
Interest in the year€96,000Accounts not yet on file: requested from the client

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

Available to Pinewood Street Finance Ltd: the safe harbour rates apply only where its financial transactions stay under the published threshold, measured by the maximum principal — here financing €3,400,000 (Tax Dept FAQ Q31, Tax Dept FAQ Q9–10).

The test — Δ.2, lending from own funds Circular 6/2023 ¶18: the GR 10-year government bond yield for December 2024 3.05% plus 3.50% = 6.55%, against 3.20% charged — 3.35 points short of the minimum: the difference is an adjustment in the return (or a corrective invoice before the books close), or the rate charged is documented at arm's length instead. Source: ECB, IRS/M.GR.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.

≈ €100,500 a year below the Δ.2 rate: the adjustment that would bring the rate to the safe harbour (€3,000,000 × 3.35 points; Circular 6/2023 ¶18) — a suggestion until confirmed.

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Evidence still outstanding: Accounts for 2025, Pinewood Street Finance Ltd, due 20 Nov 2026 — in 13 days.

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Loan to a director

Pinewood Street Finance Ltd lends to A director of Pinewood Street Finance Ltd.

WorkingValueSource
Maximum principal€400,000Director's loan account, maximum in the year (invented)
Rate charged—
Term—
Interest in the year€0Accounts not yet on file: requested from the client

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

A loan to a director: it counts towards the lender's financing threshold here, because lending is the lender's taxable activity Tax Dept FAQ Q11. No safe harbour test is shown for a loan to an individual. For the director, the Income Tax Law deems a monthly benefit of 9.00% a year on the balance at each month end ITL s.5(1)(ζ): 9%. A finance company lending interest-free is itself the pricing question — to be confirmed by the practice.

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ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Accounts for 2025, Pinewood Street Finance Ltd, due 20 Nov 2026 — in 13 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash a340465c859e · a change to it reopens every sign-off