Generally, the treasury function is part of the process of making the financing of the commercial business of the MNE group as efficient as possible. As such, the treasury function will usually be a support service to the main value-creating operation as in the case, for example, of the services provided by a cash pool leader (see Section C.2.3). Depending on the facts and circumstances of each case, such activities may be services in which case the pricing guidance on intra-group services at Chapter VII applies.
TPG2020 Chapter X paragraph 10.45
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Financial transactions, Management of group finances, Support services, Treasury functions
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