International - Transfer Pricing Aspects of Cash Pooling Arrangements in Light of the BEPS Action Plan
- V. Chand
- International Transfer Pricing Journal, 2016 (Volume 23), No 1
- 7 January 2016
The author discusses the concept, underlying commercial rationale and types of cash pooling arrangements, and then analyses and comments on the transfer pricing aspects thereof. The analysis also takes into consideration the Actions under the OECD/G20 BEPS Project related to transfer pricing. The author discusses the impact of other BEPS-related actions (domestic and treaty law changes) on cash pooling arrangements, and ultimately suggests a way forward.