With intercompany financial transactions more and more in the forefront of tax authorities’ focus, setting your transfer pricing policies in line with the arm’s length principle and in accordance with the additional guidance the OECD published in 2020 on financial transactions is increasingly important. Based on our vast experience in transfer pricing for financial transactions we have developed various solutions for managing treasury operations in tax effective manner, including comprehensive treasury policies, subscription-based credit scoring and interest rate analyses, automated cash pooling solutions, etc.

Our value proposition:

With respect to intragroup loans, irrespective of whom acts as lender, or whom acts a borrower, when no direct external market reference (CUP) exists, which typically would be so in the majority of the cases, we have developed a consistent transfer pricing policy framework, which consists of the following building blocks:

These building blocks cover all the aspects from individual intercompany loan transactions up to a general policy established by a central treasury entity.

While some building blocks might not be as relevant to your loan transactions (e.g. FX matrix when you only have EUR transactions), Tiberghien economics can assist you elaborate certain aspects of the treasury policy which might be undeveloped currently but would be worthwhile given recent attention by tax authorities as well as the aforementioned guidance by the OECD.

Obviously, our experienced and dedicated financial transactions team can also provide assistance on other financial transactions such as cash pooling, hedging, financial guarantees.

For further questions, please contact one of our specialists: Kenny or Ben