Allocation and Sharing of Synergies in Cash Pool Systems
New
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2026 (Volume 33), No. 4
Document
This article examines how synergies arising from cash-pooling arrangements should be allocated among multinational group entities under the arm’s length principle. It analyses the OECD’s transfer pricing guidance, discusses possible models for sharing cash pool benefits, and highlights the practical difficulties that taxpayers face in documenting and justifying those allocations.