Financing & treasury
Treasury transfer pricing
Treasury transfer pricing covers the arm's length pricing of every intercompany financial transaction flowing through a group's centralised treasury function, including loans, guarantees, cash pooling, hedging and factoring, recognising that treasury centres often perform genuinely valuable coordination and risk management.
The OECD's guidance on financial transactions, sometimes referred to informally as Chapter X, provides a structured framework for analysing these transactions, emphasising accurate delineation of the actual transaction, the functions performed, assets used, and risks genuinely assumed by the treasury entity rather than nominal.
A well-run treasury transfer pricing policy documents each transaction type consistently, applies appropriate benchmarking methods to loans, guarantees and cash pool balances, and revisits pricing periodically as the group's financing needs and market conditions evolve, reducing the risk of disputes arising across multiple.
In practice
What matters when applying treasury transfer pricing
- Delineate the actual transaction, not just contractual labels
- Apply OECD Chapter X principles consistently across products
- Document functions, assets and risks for the treasury entity
- Benchmark loans, guarantees and pooling arrangements separately
- Revisit the policy as financing needs and markets evolve
Frequently asked
Common questions
What does treasury transfer pricing cover?+
Every intercompany financial transaction routed through a group's centralised treasury, including loans, guarantees, cash pooling, hedging and factoring, each priced according to the functions and risks genuinely involved.
What guidance applies to treasury transactions?+
The OECD's guidance on financial transactions, informally known as Chapter X, which emphasises accurately delineating the transaction and the real functions, assets and risks of the treasury entity involved.
See how the tooling handles this in practice
Our transfer pricing tools calculate intercompany charges, benchmark financing and reconcile the intercompany ledger from your own data. Book a short walkthrough and we will show the workflow on a scenario that matches your group structure, rather than a generic demo dataset.