How a sophisticated notional multi-currency multi-entity Cash Pool brings potential to take Treasury to the next level. Besides flexibility, transparency, cost efficiency and control, a look at the strategical use of a Cash Pool to replace traditional FX hedging. Continue reading Reaching Next Level Treasury (Efficient Cross Currency Management).
The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on the valuation of cross-border transactions between associated enterprises. Let’s take closer look. Continue reading Transfer Pricing Requirements and other Potential Pitfalls. Cash Pooling Traps when not Cautious.
The Moral Hazard of Cash Pooling (a series of 4) providing context and perspectives (from the subsidiaries and the headquarters), on what scenario could potentially lead to moral hazard risk, and how to eliminate it. Continue reading Moral Hazard in Cash Pooling. The Business Case. (4/4)
The Moral Hazard of Cash Pooling (a series of 4) providing context and perspectives (from the subsidiaries and the headquarters), on what scenario could potentially lead to moral hazard risk, and how to eliminate it. Continue reading Moral Hazard in Cash Pooling. Headquarters’ & Treasury Centers’ Perspective. (3/4)
The Moral Hazard of Cash Pooling (a series of 4) providing context and perspectives (from the subsidiaries and the headquarters), on what scenario could potentially lead to moral hazard risk, and how to eliminate it. Continue reading Moral Hazard in Cash Pooling. The Subsidiaries’ Perspective. (2/4)
The Moral Hazard of Cash Pooling (a series of 4) providing context and perspectives (from the subsidiaries and the headquarters), on what scenario could potentially lead to moral hazard risk, and how to eliminate it. Continue reading Moral Hazard in Cash Pooling. Introduction. (1/4)
ING Bank Philippines and Bank Mendes Gans will centralize and manage International Container Terminal Services Inc and its subsidiaries’ global cash holdings into a cash pool. Continue reading Enhanced Global Liquidity through Notional Pooling and Payment Netting.
ING Bank Philippines and Bank Mendes Gans will centralize and manage International Container Terminal Services Inc and its subsidiaries’ global cash holdings into a cash pool. Continue reading ING, BMG to manage ICTSI global cash holdings
On July 1, 2022 The Dutch Ministry of Finance published its latest transfer pricing decree. This article specifically focuses on the decree’s high-level guidance relevant with intercompany loan and Cash Pooling. Continue reading New Dutch Transfer Pricing Decree – Relevant Action Points for Cash Pooling.
In 2020 The Dutch Tax Authorities capped the fiscal interest deduction limitation for financial institutions. As a result, the measure generally leads to a higher taxable profit and thus to a higher amount of corporation tax. And as we all know, higher costs for the bank generally lead to higher fees for the clients. The question remains, what is the perspective we should take for Cash Pools. Which interest amount is subject to this limited deductibility? Net or gross? Continue reading How Dutch Minimum-Capital-Requirements could contribute to increasing the cost of Cash Management for MNCs.
Banks worry about serving clients that could be accused of immoral and unethical behaviour, like not paying enough taxes. Politicians, society and regulators expect banks to prevent their services from being misused. Therefore, banks are expected to develop an appropriate risk model and take reasonable measures. Unexpectedly the OECD and G20 seem to assist. Continue reading Do you pay your fair share of Taxes? (Tax Integrity and KYC).
A write-up on how the OECD Two-Pillar-Solution aims at having companies pay their fair share of tax. Pillar-One: pay tax in the jurisdictions where revenue is generated. Pillar-Two: a top-up at parent level, if the overall effective tax rate drops below a certain percentage. Continue reading How far are we from a Robust Minimum Global Tax Rate?
This article provides a general summary of the latest regulatory development in China’s cash management programmes since 2012. Continue reading Summary of regulatory development for China’s cross-border Cash Pool schemes
Perspectives and insights on dealing with transfer pricing in the context of the recent OECD publication COVID-19. The OECD decided to focus on four interrelated (priority) issues (Allocation of Losses and COVID-19 Specific Costs; Government assistance programs; Comparability analysis; and Advance Pricing Agreements (APAs)) Continue reading New OECD guidance on Transfer Pricing Challenges in light of COVID-19.
In this article we look at Market Data and the Implications for Financial Transactions as guidance towards Transfer Pricing analysis in the context of COVID-19. For several years tax authorities in general have focused on financial transactions. The OECD’s guidance on financial transactions opens the door for tax authorities to not only challenge the arm’s length nature of the interest rate, but also the characterization of intercompany loans as bona fide. Greater care must therefore be taken when implementing or modifying intercompany debt funding to ensure that the financing is respected as debt and the interest expense is deductible for tax purposes. To avoid unpleasant tax consequences, a good analysis upfront is paramount. Continue reading Update on Transfer Pricing Challenges in light of COVID-19.
Hong Kong’s future as a major international financial centre hub faces a growing array of threats as the city turns into a flashpoint in the increasingly rancorous geopolitical and economic struggle between US and China. In this article, against the backdrop of COVID-19, key elements to be considered when choosing the location treasury centre. Continue reading Unveiling the key elements of setting up a treasury centre, and the outlook of Hong Kong as a treasury centre post pandemic crisis.
Exceptional times may require a review of existing Transfer Pricing Policies to determine if they are still in line with the arm’s length principle and what Third Parties would do at this moment. With pressure on budgets, it is important to have considered the impact of COVID-19 on the business and if adjustments to the Transfer Pricing Model should be made. Continue reading Transfer Pricing Challenges in light of COVID-19.
The term “Bad-bank” is not just a remnant of the 2008 financial crisis. In history we have already seen several. But what is a Bad-bank exactly, and how does it work? Continue reading How reintroducing a “Bad-bank” is the ECB’s response to COVID-19.
An innovative approach to properly disclosing Cash Pool transactions for listed companies against the backdrop of the Kang De Xin case (the fall out of which triggered the great concerns from the regulators as well as the investors). How to protect shareholders and ensure listed subsidiaries maintain independence of liquidity and avoid core capital being influenced negatively. Continue reading Proposed technical approach to achieve group liquidity centralization and separately-listed-company-funds independency
The fact that the role of Corporate Treasury evolves over time is nothing new. The fundamental task of Corporate Treasury is to ensure a company’s financial health remains. How does COVID-19 affect this task? Continue reading How COVID-19 re-emphasised that Cash is King for Treasury.
With efforts and counteracting measures to combat tax evasion and tax avoidance both at international and national level, banks are also involved. They are required by regulators to assess tax integrity of their clients and prevent that the products offered are utilized as tools for evading or aggressively avoiding tax. Also insights in tax areas relevant to liquidity management ( assessing tax integrity in the areas of substance, arm’s length and ownership). Continue reading Tax Integrity crackdown on Cash Pools unveiled, in light of the New (2021) tax initiative. Must know for Treasury Professionals. (2/2)
Background to how The Netherlands approaches a global initiative on tackling tax evasion and (immoral) tax avoidance. Specifically the measure of conditional withholding tax on interest and royalties if paid to low-tax jurisdictions (effective on January 2021) and its potential impact on. Also other tax related elements in view of multi-entity multi-currency notional Cash Pools outlined. Continue reading Withholding tax implications on Cash Pools unveiled, in light of the New (2021) tax initiative. Must know for Treasury Professionals. (1/2)
An important item, relevant to Corporate Treasury, is to gauge cautiously the corporate interests of subsidiaries and the associated risk, before joining a group’s Cash Pool. Also, subsidiaries should not simply follow instructions form the head office, but take responsibility in verifying whether or not participation in Cash Pools is possible. Why? Because failing to do so may have unexpected adverse consequences for all parties involved. Especially during times of economic downturn. Continue reading Is set-off enforcement legitimate? – Essential elements to be considered before joining a Cash Pool. (3/3)
An important item, relevant to Corporate Treasury, is to gauge cautiously the corporate interests of subsidiaries and the associated risk, before joining a group’s Cash Pool. Also, subsidiaries should not simply follow instructions form the head office, but take responsibility in verifying whether or not participation in Cash Pools is possible. Why? Because failing to do so may have unexpected adverse consequences for all parties involved. Especially during times of economic downturn. Continue reading Respecting Capital Maintenance Rules – Essential elements to be considered before joining a Cash Pool. (2/3)
An important item, relevant to Corporate Treasury, is to gauge cautiously the corporate interests of subsidiaries and the associated risk, before joining a group’s Cash Pool. Also, subsidiaries should not simply follow instructions form the head office, but take responsibility in verifying whether or not participation in Cash Pools is possible. Why? Because failing to do so may have unexpected adverse consequences for all parties involved. Especially during times of economic downturn. Continue reading Consider Corporate Benefit at subsidiary level – Essential elements to be considered before joining a Cash Pool. (1/3)
As Corona continues to spread, politicians respond with increasing countrywide containment measures. The economic costs are mounting. The stock exchanges globally experience the fastest bear market in history. Central banks worldwide take comprehensive liquidity measures. Apparently with little result. Will Corona result in a financial crisis? Continue reading The impact of Corona on global liquidity management unfolds. Best practices on how to prepare for a potential (new) financial crisis.
目前新冠病毒还在持续地在全球范围内传播，各国政治家也用越来越严厉的控制措施来回应。但这也带来了巨额的经济成本。我们所看到的是历史上绝无仅有的最快“熊”市的到来。 Continue reading 解密疫情对企业全球流动性管理的影响。跨国企业如何应对潜在的（新的)金融危机。
Are TP-professionals at risk to lose their job? As the evolving rules for profit allocation adapt a more rule-based principle and steer away from Transfer Pricing, it seems realistic. In this article a simplified summary of the statement released end January 2020 by the OECD, on the refinement of the approach on tax challenges arising from the digitalisation of the economy. Continue reading The impact of BEPS on Transfer Pricing and the Effective Tax Rate. Insights based on the January 2020 OECD update.
The right buy-in from global partners as well as from global group companies, is the first thing corporates should consider when looking at managing global multi bank liquidity. In this article a quick look at how this can work from the perspective of visibility of cash, tax, interest rates and technical innovation. Continue reading Where liquidity management is heading – or where it should head
It is argued that the OECD’s BEPS 2.0 initiative has the potential to alter the global tax landscape by changing how profits are allocated between jurisdictions (aka Pillar One) and by introducing a new globally coordinated regime for minimum tax and anti-base erosion measures. In this article, a closer look at what this all means. Continue reading BEPS 2.0 – Background for those not too familiar with the topic.
A look at the instrument of sanctions (potential consequences of non-compliance, best practices in due diligence, pitfalls and takeaways). Which, given the potential consequences, is often highly sensitive. Continue reading Trade and sanctions in the current business environment (2/2) – Best practices in due diligence.
Trade and sanctions are one of the key instruments for a couple of governments to exercise political pressure. This leads to important consequences for businesses with their activities at a global scale. Due to recent important political developments, a huge increase in the focus on trade and sanction issues can be noticed. What does this mean in terms of policies? Continue reading Trade and sanctions in the current business environment (1/2) – The instalment of the new European Commission.
With the Directive on Payment Services 2 (PSD2), the EU seeks to open up payment markets to new entrants leading to more competition, greater choice and better prices for consumers. It puts in place comprehensive rules for payment services, with the goal of making international payments (within the EU) as easy, efficient and secure as payments within a single country. This post is a high level overview of the impact of the recent amendments pertaining to Foreign Exchange on electronic payments. Continue reading EU Cross Border Regulations Update on Foreign Exchange (PSD2-amendment) effective April 2020.
Many have called it the most important number in the world, but soon it will disappear, the Intercontinental Exchange London Interbank Bank Offered Rate, otherwise known as LIBOR or ICE LIBOR (previously BBA LIBOR). LIBOR is the most widely used benchmark for short-term interest rates in the world. Banks and corporates rely on it extensively. So if LIBOR is so popular, why will it disappear and what is replacing it? What happens to LIBOR based products if LIBOR is no longer available? Continue reading The end of LIBOR is coming – a quick update on IBOR transition.
Nowadays more and more scrutiny is asked to combat base erosion and profit shifting attempted by multinational corporates. The usual suspect in this combat is transaction conducted among group companies. More specifically, authorities look at lending and borrowing activities between group companies and seek for any possible base erosion and profit shifting. This can lead to misinterpretation and confusion. In this post a closer look. Continue reading BEPS-combat attacks “innocent” Cash Pooling.
A series of three articles from the viewpoint of Corporate Treasurer in China multinational corporates (MNCs). Particularly in respect of the current capital control in China, China headquartered MNCs have to distinguish the onshore and offshore market. Therefore they have to use different tools to manage group liquidity by separating mainland China and rest of the world. (1) comprehensive considerations of centralizing group liquidity management; (2) understanding in setup Singapore Treasury Center; and (3) probe into different notional cash pooling forms. Continue reading “Chinese best practices in Treasury” by Chen Chao.
前文谈到，上市公司规则并未明确禁止上市公司参与任何形式的资金池。但不同银行提供的资金池产品有差异，企业财资人员需要仔细研究如何对资金池进行合理披露。 Continue reading 上市公司的资金集中与合理披露——方案初探（2/2）
本文中我们将探讨某中国企业的上市公司即便有122亿人民币现金存款，却无法偿还10亿到期债券；以及监管机构是如何看待其产生的负面影响。 Continue reading 您的资金池是否合理披露？谈谈和资金管理有关上市公司的关联交易的问题（1/2）
There are no specific rules that prohibit listed companies to participate in any kind of Cash Pool. But as there are many different kinds of Cash Pools provided by many different banks, it pays to take a closer look at exactly how disclose should take place.
This article takes a closer look at a more advanced Cash Pool structure, whereby no physical movement of funds is required (so called multi-currency multi-entity notional Cash Pools). Continue reading The way forward for listed companies – achieving liquidity concentration and respecting disclosure rules. (2/2)
A closer look at how a (publicly) listed subsidiary of a Chinese multinational could not repay a RMB 1 billion matured bond, even though RMB 12.2 billion of free cash was recorded. And how this attracted (negative) regulatory attention. Continue reading Is the Cash Pool properly disclosed? Must know for Treasurers. (1/2)
China and the US. For months now the two countries have been involved in an escalating trade war. The US imposed tariffs on Chinese exports, China responded with tariffs on US exports. But right now, there is an even bigger war between these two countries. And this war is for the future. Whoever controls 5G, is going to have an enormous strategic advantage in the future. Continue reading Race to 5G (the future of the internet).
每天有超过1.5亿美元流入世界各地的英迈国际（Ingram Micro）公司，因此公司必须要拥有对现金的集中与控制以及快速调剂不同主体间的资金。本文中，该公司财资主管Erik Smolders和门德斯甘斯银行（Bank Mendes Gans，简称BMG）美国地区客户与产品部门执行总裁Bertie Sanders解释了英迈国际是如何设立全球虚拟资金池，以便公司能够灵活地调剂不同主体间的资金而无需发生公司间贷款。他们还概括了这一全球架构的益处，包括大幅减少外汇风险与成本、改善流动性，同时不影响公司现有合作银行的利益。 Continue reading 打破常规： 构建全球流动性管理的核心
With over $150m flowing into Ingram Micro subsidiaries across the world on a daily basis, having centralised visibility and control over that cash – and being able to move it swiftly between different legal entities is a must. Here, Erik Smolders, the company’s Treasurer, and Bertie Sanders, Managing Director, Clients & Products USA, Bank Mendes Gans, explain how they set up a global notional cash pool that affords Ingram Micro the flexibility to move funds between entities without intercompany loans. They also outline the benefits of this overlay set-up, ranging from significant reduction of FX exposures and costs to working capital improvements – all without ruffling the feathers of existing banking partners. Continue reading Building a Global Multi-Currency Liquidity Management Backbone – Thinking Outside the Box.
By re-imposing the previously lifted sanctions on Iran, the US has brought the toughest challenges to bank compliance yet. This article looks at the reasons why international banks have to take compliance risk so very seriously. Continue reading Sanction risk and KYC. Why it matters so much to international banks. Lessons learnt!
自美国重启伊朗制裁，银行合规遇到了前所未有的挑战。本篇文章旨在解释为何跨国银行对制裁国家合规风险如此重视。 Continue reading “制裁国家风险”与“了解你的客户”，为何跨国银行如此重视?
巴塞尔协定三对银行产品的影响以及银行采取的应对措施是既统一也各异，就好比每个人都可以选择穿西服，但西服可以是礼服式的也可以是休闲西服，可以是平价款的优衣库也可以是优雅时尚的阿玛尼。西服是必须要穿的，尺码也给确定好了，每个人预算不同，而且在对穿西服这件事上每个人风格也不同，所以最后在晚会上每个人选择款式都不会是一样的。 Continue reading 巴塞尔协定三是如何影响虚拟资金池？说说你不得不知道的事
A series on what Treasury Professionals should know about Basel-3. This article explains why and how Risk-weighted Assets (RWA) affect Cash Pools (in particular Multi-Currency Multi-Entity Cash Pools). Also: the added value of RWA now that banks already need to meet ratios like Liquidity Coverage Ratio (LCR) and Leverage Ratio (LR). Continue reading Different treatment Single-Entity vs. Multi-Entity Cash Pools for Risk-Weighted Assets (RWA). Must-know about Basel-3. (4/4)
A series on what Treasury Professionals should know about Basel-3. In this article the timing of Lehman Brothers’ collapse and the introduction of Basel-3. Also a closer look at how Asia, in particular Singapore, got dragged in. Continue reading What was first? Lehman Brothers’ collapse or Basel-3? And how did Asia get dragged in? (3/4)
What Treasury Professionals should know about Basel-3. In this article “Leverage Ratio (LR) and Notional Cash Pools”. Many have overheard that also the LR seems at odds with Notional Cash Pools. What does it mean? Why and how does it hurt banks? Many have an opinion, but only few know the facts. This article explains. Continue reading Must-know about Basel-3: Leverage Ratio (LR) and Notional Cash Pools. (2/4)
What Treasury Professionals should know about Basel-3. Many have overheard that the LCR seems at odds with Notional Cash Pools. What does it mean? How is it calculated? Why and how does it hurt banks? Many have an opinion, but only few know the facts. This article explains. Continue reading Must-know about Basel-3: Liquidity Coverage Ratio (LCR) and Notional Cash Pools. (1/4)
On May 11, the Dutch Ministry of Finance published a new Transfer Pricing Decree. But don’t think this is an isolated case, applicable only to Dutch MNCs (Multinational Companies). This is a coordinated approach by Tax Authorities globally. Hence relevant for MNC’s worldwide. This article takes a closer look. Continue reading Transfer Pricing re-calibrated: “Value creation”. The new Dutch TP Decree.
Many have called it the most important number in the world, but soon it will disappear, the Intercontinental Exchange London Interbank Bank Offered Rate, otherwise known as LIBOR or ICE LIBOR (previously BBA LIBOR). LIBOR is the most widely used benchmark for short-term interest rates in the world. Banks and corporates rely on it extensively. So if LIBOR is so popular, why will it disappear and what is replacing it? What happens to LIBOR based products if LIBOR is no longer available? Continue reading Britain scraps world’s #1 benchmark LIBOR (from end of 2021) – but it is not solely a London problem!
Must read for those involved in Client Tax Integrity. Paradise Papers in relation to China. All-inclusive research into why Chinese multinational companies are registered in tax havens. A closer look at the Chinese expansion strategy, and why offshore entities in tax havens fit that strategy. A detailed examination of the advantages of tax havens and the resulting Chinese selection criteria applied to territories for overseas entities. This against the backdrop of tax evasion and aggressive tax avoidance. Continue reading Comprehensive Probe Into How And Why Chinese Companies Use Tax Havens And Offshore Financial Centres – A Tax Integrity Reference Work.
Whilst the treasury profession remains largely male-dominated, I recently had the pleasure to welcome an engaging young lady for a (very) short internship. Eva. And as she enquired about Treasury as we went along, I realized how difficult it is, for those making career choices at school, or those just starting out in the professional world, to comprehend what Treasury actually encompasses. How it evolves and what the prospects are for the future. Hence a simplified perspective for those not too familiar with Treasury. Continue reading Introducing Treasury to Millennials – Role & Evolution.
China has imposed new tariffs on products imported from the US. It is a direct response to President Trump’s announcement of charges on steel and aluminium imported in to America. Beijing says the move is to safeguard the country’s interests. The main concern is that the situation could escalate further, if the U.S. goes ahead with its plan of tariffs on Chinese imports. According to Washington this is a retaliation for years of alleged intellectual property theft. Continue reading Markets fall as US-China trade-war-fears grow.
With roughly 500 pages, the Tax Cuts and Jobs Act introduces hundreds of changes to the US tax code. It will affect every business and every individual in the US, foreign companies investing in the US as well. It reconfigures everything. Corporate tax plays a very prominent role. Continue reading Tax Cuts and Jobs Act “a tax-reform-law that promises to redefine the tax landscape in the US”.
The war of words between Donald Trump and North Korea has brought volatility back into markets. The geopolitical uncertainty affects global markets across the board, including equities, bonds and gold. How we feel about the market risk? How close are we to war? What is the significance of the military preparations and deterrents? These and similar questions have become more common than at any time since the financial crisis. Continue reading How close is the world to war? The alarming reality.
A closer look at why the Japanese economic landscape (aging and shrinking population, near flat GDP and retained earnings leads to an increased focus on global cash management. But also a look at if Japanese banks can still catch-up in order to meet demand? What serious challenges do newcomers to this area face. Especially a diversified client-base may prove to be an “Achilles’ heel”. Continue reading Japanese Economy Sets Stage For Global Cash Management. Who can service?
Asia. One of the world’s fastest growing regions today. But it’s taking a long and hard road to get here. 20 years ago much of Asia went through a devastating financial tsunami that has shaped much of how the region operates, even today. In part 3, we look back and forward. Continue reading Asia’s Financial Crisis, The 20th Anniversary (3/3) – Retrospective and Forward Looking.
Asia. One of the world’s fastest growing regions today. But it’s taking a long and hard road to get here. 20 years ago much of Asia went through a devastating financial tsunami that has shaped much of how the region operates, even today. In part 2, we look at the countries affected most. Continue reading Asia’s Financial Crisis, The 20th Anniversary (2/3) – Countries Affected Most.
Asia. One of the world’s fastest growing regions today. But it’s taking a long and hard road to get here. 20 years ago much of Asia went through a devastating financial tsunami that has shaped much of how the region operates, even today. In part 1, we look at how events unfolded. Continue reading Asia’s Financial Crisis, The 20th Anniversary (1/3) – How Events Unfolded.
Every five years the eyes of the world’s turn to China as the ruling Communist Party holds its Congress. Reflecting on General Secretary Xi Jinping’s last years and what might be next for China. The 19th Party Congress. Continue reading A look at China’s 19th Communist Party Congress through western eyes.
All roads lead to Beijing as we look at China’s generation defining “One Belt, One Road” policy, an endeavour that, if successful, will interweave the economic destinies of 3.8 billion people (over half of the global population), across 65 countries. The cost is projected at a mindboggling USD 4 trillion – equivalent to launching 27 International Space Stations, building 10 complete US interstate systems, or digging 180 Chunnels (the Channel Tunnel between the U.K. and continental Europe). No matter how you slice it, China is primed to head-up the largest infrastructure investment project the world has ever seen. Continue reading One Belt, One Road – The giant in The East needs a better PR-firm on the case.
A survey conducted by the European Commission revealed that 80% of the respondents answered with “no”, when they were asked if they were considering buying a financial product outside their own EU-county. This seems to be, the survey continues, because in the near future “they can purchase all financial products in their own country”. Could it be that PDS2 influences their decision? How does this then supposedly work? Last but not least, is this a threat to banks in general? Continue reading How can technology influence the changing relationship between Bank and Treasury – PSD2 explained.
Being rewarded makes us feel good. When exposed to a rewarding stimulus, the brain responds by increasing release of the neurotransmitter dopamine. Deep within we all hope to receive some sort of payoff for the good that we do. Truth be told, in our working life, there is usually no satisfying payoff. However, there seems to be an exemption. According to the US Department of Justice there is one industry that rewards its employees for their hard work, the money laundering industry. It accumulates more money than the electronics industry, the entertainment industry and the pharmaceutical industry combined.
Now you may be thinking, ….. wait! …… money laundering, ….. isn’t that illegal? Minor technicality. However, it is exactly this technicality that leads governments globally to try to suffocate this flourishing industry, whilst others’ strategy is to bypass the defences and become the most successful human beings on earth. Continue reading Money laundering as an adventure!
The outcome of the referendum is clear, the U.K. wants out. Fast. However, the whole process of the Brexit has not even started yet. Hard statements during public appearances set the scene. Is this negotiation rhetoric or something else? What are the consequences we could anticipate? What exit scenarios are available? How does the legal framework interfere? Continue reading Brexit? Yes! But keep in mind, until you’re out, you’re in!
The Cayman Islands may be beautiful, but the world’s wealthy, and some of the world’s biggest businesses are there for another reason, its financial system. This article sheds light on how this works, against the backdrop of tax avoidance, the moral aspects, and financial institutions’ Customer Due Diligence / Know Your Customer. Continue reading Who and What Determines Offshore Ethics? – A perspective on tax avoidance, KYC v2.0
If the price isn’t right, suspicion of Corporate Tax Avoidance could rise.
A discussion paper against the backdrop of OECD’s “Transfer Pricing Reporting”. The recent crises and some scandals shed light on the risk that a certain way of applying transfer pricing was jeopardizing the arm’s length principle itself. That’s why the OECD aims at redrafting the guidelines. Transfer pricing has become one of the main risks to be addressed and managed by MNCs. How does this potentially affect Treasury? What are best practices? Continue reading Transfer Pricing? Keep it at arm’s length! (BEPS Action #13)
Qualification mismatches can be powerful tools to reduce tax costs in a tax planning structure. How the OECD proposes to neutralize the effects of hybrid mismatch arrangements may/will impact MNC’s. This article provides a technical analysis. Continue reading Dealing with OECD’s “Neutralizing the effects of hybrid mismatch arrangements” (BEPS Action #2).
November 3rd this year, the IRAS (Inland Revenue Authority of Singapore) published an update of its guidelines as it pertains to related party transactions. Starting 2018, if the value of related party transactions in the audited accounts for the financial year exceeds a fairly low threshold of 15 million SGD, certain details of these related party transactions must be reported. Continue reading A Holistic view on Transfer Pricing – IRAS follows the Global Trend.
Singapore’s tax authority roll out new rules on transfer pricing reporting. Multinationals will have to invest in people and resources to ensure they are compliant. An interview with Ann Shi for the Corporate Treasurer Asia. Continue reading Singapore’s new rule on MNC transfer pricing ups reporting burden – In interview with The Corporate Treasurer – by Ann Shi.
A top issue on the minds of treasures today are the proposed Section 385 Regulations – hereafter proposed regulation. Initially proposed last April, the regulation is designed to curb inversions. Continue reading Effects of the proposed (US) Section 385 Regulations.
Blockchain is one of the buzz words of 2016. By the financial industry, blockchain is seen as the future. It’s impact is compared to how internet has revolutionized the computer and global communications, like nothing before. In (originally not planned) part 5, a look at Corporate Treasury. Continue reading Blockchain and Corporate Treasury (5/4).
Blockchain is one of the buzz words of 2016. By the financial industry, blockchain is seen as the future. It’s impact is compared to how internet has revolutionized the computer and global communications, like nothing before. In part 4, a look at the impact on the financial sector. Continue reading Impact of blockchain on the financial sector (4/4).
Blockchain is one of the buzz words of 2016. By the financial industry, blockchain is seen as the future. It’s impact is compared to how internet has revolutionized the computer and global communications, like nothing before. In part 3, a look at the regulatory environment. Continue reading Thoughts around the regulatory environment on blockchain (3/4).
Blockchain is one of the buzz words of 2016. By the financial industry, blockchain is seen as the future. It’s impact is compared to how internet has revolutionized the computer and global communications, like nothing before. In part 2, a look at blockchain transparency, security and governance. Continue reading Blockchain Transparency, Security and Governance (2/4).
Blockchain is one of the buzz words of 2016. By the financial industry, blockchain is seen as the future. It’s impact is compared to how internet has revolutionized the computer and global communications, like nothing before. In part 1, blockchain demystified. Continue reading Blockchain demystified – What is Blockchain? (1/4).
Regulators expect financial institutions to become the gatekeepers for preventing the misuse of the financial system for activities like money laundering and terrorist financing. Therefore compliance-risk, as well as controlling integrity-risks, has become one of the most significant ongoing concerns for financial-institution executives. Tighter compliance regulations have challenged financial institutions in a variety of ways. Continue reading Customer Due Diligence and KYC – Understanding Your Bank’s Challenges.
A corporate treasury focused purely on executing transactional activities is a rare thing – if one still exists. The role of treasury has developed into a far broader function and phases such as strategic advisor are now thrown into the mix. But what does this mean and how does selecting the correct treasury structure enable an advisory function? Treasury Today Asia looks at how different treasury models, including hybrid centralisation, have evolved to fulfil the multiplying needs placed on different treasuries. An interview with Treasury Today Asia. Continue reading Treasury models are adapting for purpose – In interview with Treasury Today Asia.
For offsetting purposes under IAS 32, the set of requirements is, and always has been; (i) a legal basis, (ii) the legal enforceable right to offset (iii) the intention to settle. In the past it was argued that, though it seems a contradiction in termini, the intention can only be demonstrated by actual settlement, otherwise there is no intention. Hence the latter was facilitated for cash pools by various ways of physically offsetting balances (transfers) at a certain point in time in the year. Looking at how IFRIC requirements can be met. Continue reading IFRIC – Meeting the requirements.
Just one evolutionary path or multiple? Biological evolution can be described as “change in the heritable traits of populations over successive generations”. Like Charles Darwin formulated the scientific theory of evolution by natural selection, published in his book On the Origin of Species (1859), evolutionary processes give rise to diversity at every level. In other words, there is more than one way forward. Continue reading How does Treasury evolve? Just one evolutionary path or multiple?
One of my previous publication outlined insights in Asia’s treasury focus and priorities. As it is nearly impossible to realize proper treasury management when group companies settle their obligations at random, or worse, not at all, I indicated to spend some time on the technique that can be used to address this “Netting of payables and receivables, or just “Netting” for short. Continue reading How Netting supports the business – understanding the challenges.
Research in Asia reveals what Treasury will focus on in the period ahead. Though a lot of time is traditionally spent on mapping innovation and new development, it is sometimes quite difficult to actually push for change. How innovative are we, and how does price factor in to our decision making process?
And, if we’re going to embark on the journey of change, maybe we should take a closer look at what we really want to achieve; go back to basics and most of all try to keep it simple. Improvement could already be achieved by just revisiting those procedures and processes we tucked away and take for granted. But keep an eye on the business Continue reading Insights in Asia’s Treasury focus and priorities.
An ING / Bank Mendes Gans case study by Raymond Zhang, assistant general manager, Treasury division, Shenzhen based China International Marine Containers (Group) Ltd. This is the third of three articles published by ING in Treasury Management International (TMI) providing in-depth insights into the challenges, opportunities and solutions for corporations expanding from their home market in Europe or Asia into new territories. Continue reading China International Marine Containers (CIMC) pioneer in highly innovative cash pooling.
Connecting regions, creating competitive advantage. This is the third of three articles in TMI published by ING that provide in-depth insights into the challenges, opportunities and solutions for corporations expanding from their home market in Europe or Asia into new territories. (November 2014) Continue reading Pioneering best practices in Global Liquidity and Risk Management – In interview with TMI Magazine & CIMC.
In recent months much has been written on the renminbi ‘s (RMB) increasing speed of internationalisation, following initiatives by the People’s Bank of China (PBOC). From a liquidity management aspect this might seem very promising; embedding RMB in offshore cash pools sounds like a wish come true for many multinational corporations (MNCs). However as this article explains, treasurers who plan on making early use of these opportunities could find that China’s foreign exchange (FX) controls are still in effect. Continue reading Unwrapping Renminbi from ‘Red Tape’: A Perspective on China’s Currency.
Figures show that corporate cash balances at many businesses have grown over the past few years. Companies aimed to protect their lifelines and reduce liquidity risk during the prolonged financial crisis that developed more than five years ago. At present, with the financial landscape still unclear, cash balances remain very high; in fact many companies appear to be holding more cash than before the crisis. Continue reading A Strategy for Setting Free Trapped Cash.
Asia hosts some of the most sophisticated cash management systems; but does a multi-currency pool make sense for your company? CT looks into the pros and cons. Continue reading PRIMER: Multi-currency pooling – In interview with The Corporate Treasurer – by Dan Bland.
TREASURY INSIGHTS & CURRENT TOPICS 