HMRC publish cash-pooling guidance | KPMG | UK
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HMRC publish cash-pooling guidance

HMRC publish cash-pooling guidance

The guidance covers the key issues associated with the transfer pricing aspects of cash pooling.



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On 6 February, HMRC published guidance on the transfer pricing aspects of cash pooling. This is intended to provide guidance to both taxpayers (and their advisors) and HMRC specialists and client relationship teams. It has been structured to cover a full range of issues associated with cash pooling, from its most basic form to some of the more complex issues associated with a substantial cash pool header.

The guidance includes commentary on:

  • setting interest rates;
  • the consequences of netting balances;
  • the possible long-term debt implications for cash pools; and
  • withholding tax issues associated with cash pools.

The new guidance has been subject to a lengthy period of development within HMRC and highlights the fact that HMRC are now more focused than ever on the transfer pricing implications of related party financing transactions. In addition to the new guidance, we have also started to see more ‘live’ enquiries from HMRC in relation to cash pooling arrangements and the role of group treasury entities.

If you have any questions or comments in relation to this guidance or would like to discuss the transfer pricing considerations for cash pooling or group treasury functions in more detail, please get in touch with your usual KPMG contact or one of the named contacts below.


For further information please contact :

Sarah Beeraje

John Monds

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