Tag: Coordination activities

TPG2022 Chapter X paragraph 10.46

Similarly, the treasury may act as the contact point to centralise the external borrowing of the MNE group. External funds would then be made available within the MNE group through intra-group lending provided by the treasury. On prevailing facts and circumstances, guidance in paragraph 1.188 of Chapter I would apply to these situations and the treasury would be expected to receive an arm’s length fee for its coordination activities ...