Application of the Arm's Length Principle to Physical Cash Pooling Arrangements in Light of the OECD Discussion Draft on Financial Transactions

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Serval ID
serval:BIB_E753663437B4
Type
Article: article from journal or magazin.
Collection
Publications
Institution
Title
Application of the Arm's Length Principle to Physical Cash Pooling Arrangements in Light of the OECD Discussion Draft on Financial Transactions
Journal
Intertax
Author(s)
Haller A., Chand V.
ISSN
0165-2826
Publication state
Published
Issued date
10/03/2019
Peer-reviewed
Oui
Volume
47
Number
4
Pages
349-364
Language
english
Abstract
Although cash pooling arrangements are one of the most important tools to facilitate efficient liquidity management within multinational enterprises (MNEs or group companies), the application of the arm’s length principle to these arrangements has not been sufficiently explored as yet.Against this background, this article critically discusses the transfer pricing aspects of physical cash pooling arrangements, especially in the light of the OECD’s recent Discussion Draft on Financial Transactions. Specifically, the article discusses the application of the arm’s length principle to cash pooling borrowings and deposits, guarantees issued in the context of the pooling arrangement, remuneration of the cash pool leader (CPL) as well as allocation of the cash pool benefit, in particular, the netting benefit and the volume discount. The authors also provide comments on the impact of the negative interest rate environment on cash pooling arrangements.
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03/12/2018 15:59
Last modification date
04/09/2019 17:17
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