Financial Arrangements
Intercompany financial transactions - such as loans, cash pooling, and guarantees - are increasingly in focus from tax authorities around the world. With the OECD’s Chapter X guidance now setting clearer expectations, businesses need to ensure that financial arrangements are not only commercially sound, but also appropriately priced, consistently documented, and audit-ready.
At CAVOK Advisory, we offer a full suite of services to help you navigate the technical and practical aspects of intercompany financing. Whether you’re establishing new arrangements or reviewing existing ones, we ensure that your structures reflect economic reality, align with treasury operations, and meet compliance obligations across jurisdictions.
Intercompany Loans
We support you in determining arm’s length interest rates and advice on loan terms and conditions, thin capitalisation risks, and appropriate documentation under OECD guidelines.
Guarantees
We help you value guarantees and determine appropriate fees using recognised methodologies, while ensuring risk and return considerations are documented.
Training for Finance Team(s)
We help train your finance team setting and monitoring interest rates etc. in line with TP requirements, equipping them with practical tools and guidance bridging the gap between compliance and day-to-day execution.
Cash Pooling
We help you assess your physical or notional cash pool setup, define roles and responsibilities (leader vs. participants), allocate synergies, and help document in a way that’s transparent and defensible.
Pricing Policies
We help you design practical transfer pricing policies for intercompany financing to ensure consistent and defensible pricing.
Credit Ratings
We help you prepare internal credit ratings for group entities using recognised methodologies, forming the foundation for setting rates.
End-to-End Documentation
We provide support for financial transaction documentation, risk assessments, audit readiness, and alignment with your group treasury policies.