TPI 2018, 293
The transfer pricing of cash pooling arrangements has, as case law evidences, attracted considerably more attention in recent years from tax authorities and is getting more and more complex. More jurisdictions are expected to introduce specific guidance, following the impending release of the OECD Discussion Draft on Transfer Pricing of Financial Transactions. As a result, a higher level of scrutiny of such arrangements is anticipated. This article provides an overview of the evolving transfer pricing aspects of cash pooling, highlighting the main relevant and complex issues that need to be addressed.