# Local File: Pinewood Street Pharma Cyprus Ltd
Financial year 2025. Prepared with tp.alp for Pinewood Street Pharma.

> **DRAFT — NOT SIGNED OFF.** 3 of 3 sections are not confirmed. Not for filing.

## 1. The local entity
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: Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Tax Department, Frequently Asked Questions about Transfer Pricing, question 52; OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash bfb9e66d09e84f6d0d482d22ed5a7486d9fd1b5a0b18b691499ce3e18a77ddaa._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Purchase of finished medicines
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 Transfer Pricing Guidelines 2022, paragraphs 3.57, 3.60 (and 3.61–3.62); OECD Transfer Pricing Guidelines 2022, paragraph 1.36_
_Status: draft. Content hash 029676ac0d820aac306b962a7a419fcab6778a89602e06e6c8c94218f268bcea._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
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 Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash cb33ddcafbb155caeff48bee834064e09b20b86151b2e0990649cb7872ed40b7._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet