Chapter INTM503010
| Published date | 09 April 2016 |
| Record Number | INTM503010 |
| Court | HM Revenue & Customs |
| Issuer | HM Revenue & Customs |
The terms “treasury company” and “group finance company” can cover a wide range of activities, from a simple conduit through which funds flow, to a company with a complex range of activities. The approach to determining the appropriate arm’s length price for the functions undertaken and transactions performed by treasury and group finance companies is no different from other transfer pricing enquiries, in that it requires the application of an authorised OECD approach (see INTM463000).
The terms treasury company and finance company can be interchangeable so it would be unwise to make assumptions about risks and functions based on how...
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