Determining the arm’s length interest rates for the cash pool intra-group transactions may be a difficult exercise due to the lack of comparable arrangements between unrelated parties. In this context, banking arrangements involving the cash pool leader, taking into account functional differences between the bank and the cash pool leader, and the options realistically available to the cash pool members may inform the identification of comparable interest rates in the transfer pricing analysis.
TPG2022 Chapter X paragraph 10.145
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter X: Transfer Pricing Aspects of Financial Transactions | Tag: Allocation of synergy benefit, Benefit test, Cash pool, Cash pool members, Financial transactions, Lack of comparables, Options realistically available, Pricing cash pool transactions, Treasury functions
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