Company T, a member of MNE Group Y, performs as the MNE group treasury entity and undertakes a range of different financial transactions both intra-group and externally. Company T’s main purpose is to provide treasury services to the other entities within the MNE group including strategy and management of group liquidity. T is responsible for raising finance across the MNE group by issuing bonds or borrowing from third party banks and arranges intra-group loans to meet the funding needs of other group members as necessary.
TPG2022 Chapter X paragraph 10.138
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By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter X: Transfer Pricing Aspects of Financial Transactions | Tag: Cash pool, Cash pool leder, Example 2 - cash pool leader, Financial transactions, Pricing cash pool transactions, Treasury functions
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- TPG2022 Chapter X paragraph 10.142It should be borne in mind that the other group members which transact with T would still only do so if this left them no worse off than their next best option....
- TPG2022 Chapter X paragraph 10.141Accordingly, T should be compensated for the functions it performs and the risks it assumes in accordance with the guidance in Section C.1. This may include earning part or all of the spread between the borrowing and lending positions which it adopts....
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- TPG2022 Chapter X paragraph 10.132The following examples illustrate the principles described above....