The Resource Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions

Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions

Label
Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions
Title
Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions
Creator
Subject
Language
eng
Summary
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
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 47 (2019), no. 4 ; p. 349-364
http://library.link/vocab/creatorName
  • Haller, A
  • Chand, V
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • cash pooling
  • transfer pricing
  • arm's length principle
Label
Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions
Instantiates
Publication
Label
Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions
Publication

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