Application of the arm's length principle to physical cash pooling arrangements in light of the OECD Discussion Draft on Financial Transactions Alexander Haller & Vikram Chand
By: Haller, Alexander
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Contributor(s): Chand, Vikram.
Material type: 
ArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | OPERACIONES FINANCIERAS | PRINCIPIO DE PLENA COMPETENCIA | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO
In:
Intertax v. 47, n. 4, April 2019, p. 349-364Summary: 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.
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Resumen.
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.
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