KPMG article: Common transfer pricing challenges in cash pooling

Cash pooling is not observed between unrelated parties, which presents challenges. 

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June 12, 2025

Cash pooling arrangements are more intricate than simply setting arm’s length interest rates and book-keeping of deposits and loans. Cash pooling is not observed between unrelated parties, making it challenging to have an optimum yet robust transfer pricing policy.

Read a June 2025 article* prepared by KPMG LLP tax professionals that explores explore some common transfer pricing challenges faced by multinationals in structuring their cash pooling arrangements.

*Reproduced with permission from Tax Management International Journal, 6/12/2025. Copyright ® 2025 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com

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