As indicated in paragraph 1.159, the determination of the results that arise from deliberate concerted group actions must be established through a thorough functional analysis. Accordingly, in the context of cash pooling arrangements, it is necessary to determine (i) the nature of the advantage or disadvantage, (ii) the amount of the benefit or detriment provided, and (iii) how that benefit or detriment should be divided among members of the MNE group.
TPG2020 Chapter X paragraph 10.120
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Cash pool, Delineation, Financial benefit, Financial transactions, Group synergies, Synergies, Treasury functions
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