Intra-group loans, guarantees, cash pools, captives. OECD Chapter X through the lens of the Petruzzi monograph.

FAQ

Questions on transfer pricing for financing.

• What is the arm's length range for intra-group loans?

  The arm's length range depends on the borrower's stand-alone credit rating, the loan's term and seniority, market reference rates, and any implicit group support. OECD Chapter X (2020) provides the framework; practitioners benchmark against bond databases, broker quotes, and observed comparable issuances.

• How is implicit support applied to a wholly-owned subsidiary?

  Implicit support reflects the credit uplift a subsidiary receives from being part of a creditworthy group. Per OECD Chapter X paragraphs 10.78-10.95, the analysis distinguishes passive association (group membership alone) from active financial support, with only the latter altering the stand-alone rating.

• What documentation does a cash pool need?

  Cash pool documentation explains the header's substance, the synergy benefit distribution, the deposit and borrowing rates, and the duration of routine versus structural balances. The OECD's 2020 guidance treats short-term balances differently from longer-term loans masquerading as pool positions.