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Engagements › Pinewood Street Pharma › 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.

Pinewood Street Pharma Cyprus Ltd

DRAFT — not signed off. 3 of 3 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 3 sections are confirmed, 3 to go

1. The local entity

Draft

Pinewood Street Pharma Cyprus Ltd is a company resident in Cyprus. Limited-risk distributor of prescription medicines.

Group: Pinewood Street Pharma. Entities in the group: Pinewood Street Pharma Cyprus Ltd (CY); Pinewood Street Finance Ltd (CY); Pinewood Street Pharma AG (CH); Pinewood Street Hellas S.A. (GR); A director of Pinewood Street Finance Ltd (CY).

Documentation duty: goods of €8,400,000 exceeds the €1,000,000 threshold the Tax Department publishes.

Sources: ITL s.33(7)–(8); Tax Dept FAQ Q52; OECD Ch. V, Annexes I–II. Rests on: Obligations: Pinewood Street Pharma Cyprus Ltd (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Obligations: Pinewood Street Pharma Cyprus Ltd.

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

Evidence still outstanding: Year-end true-up calculation for the distributor, due 9 Nov 2026 — in 2 days.

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

HashContent hash bfb9e66d09e8 · a change to it reopens every sign-off

2.1 Purchase of finished medicines

Draft

Purchase of finished medicines: Pinewood Street Pharma AG to Pinewood Street Pharma Cyprus Ltd, €8,400,000 in the year.

Method: Transactional net margin method, operating margin. Tested party: Pinewood Street Pharma Cyprus Ltd.

Interquartile range on 10 accepted comparables (inclusive quartiles): 1.59% to 2.64%, median 2.52%. Result of the tested party: -0.80%, below the range.

Year-end true-up (a suggestion until confirmed): €305,200 upwards for Pinewood Street Pharma Cyprus Ltd, to the contract's 2.00%; the 2025 books are closed, so it is an adjustment in the 2025 return — how, in Cyprus, is to be confirmed by the practice.

Written agreement: Distribution agreement, Pharma Cyprus Ltd; checked against the file (1 point differs).

Risk allocation: Principal bears inventory and market risk; the distributor is limited-risk.

Functional analysis: Pinewood Street Pharma Cyprus Ltd as a limited-risk distributor.

Sources: OECD 3.57, 3.60; OECD 1.36. Rests on: Benchmarking: Purchase of finished medicines (draft), Agreement: Purchase of finished medicines (draft), Functional analysis: Purchase of finished medicines (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Benchmarking: Purchase of finished medicines, Agreement: Purchase of finished medicines, Functional analysis: Purchase of finished medicines.

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

Evidence still outstanding: Year-end true-up calculation for the distributor, due 9 Nov 2026 — in 2 days.

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

HashContent hash 029676ac0d82 · a change to it reopens every sign-off

3. Financial information

Draft

Financial information used in the analysis: Trial balance, Pharma Cyprus Ltd (SHA-256 48879edc976cae63…).

Purchase of finished medicines: operating margin earned -0.80%.

Sources: OECD Ch. V, Annexes I–II.

Sign-Off

ReviewedVerifiedConfirmed

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

Evidence still outstanding: Year-end true-up calculation for the distributor, due 9 Nov 2026 — in 2 days.

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

HashContent hash cb33ddcafbb1 · a change to it reopens every sign-off