Germany: Global-China cash pooling and transfer pricing implications

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Germany: Global-China cash pooling and transfer pricing implications

andresen.jpg

tao.jpg

Ulf Andresen


Yu Tao

The past year saw major movements towards liberalising the currency of the world's second largest economy, the Chinese Yuan or Renminbi (CNY). Such movements include the simplification of cross-border Yuan transaction procedures by the People's Bank of China, guidance for the Shanghai Pilot Free Trade Zone, and the opening up of global CNY offshore centres including Frankfurt. German multinationals, some with huge accumulated CNY cash surpluses in China have had difficulty with cash repatriation. They now have the opportunity to use their surplus cash by connecting their Chinese and global cash pools. Successful pilot cases have been launched both within and outside the Shanghai Pilot Free Trade Zone (entities in this zone enjoy simplified procedures) and now banks are offering cash pool linkage as a product.

Transfer pricing challenges arise from the determination of arm's-length cash-pooling interest rates for CNY, mainly because of the co-existence of onshore and offshore interest and currency exchange systems. The two markets deliver different third-party benchmarks and mixed opportunity costs for the fund providers. On the other hand, fund users are able to borrow alternative free-trade currencies at lower interest rates. Here the rate difference is primarily driven by the evolving outlook of CNY exchange rates. This situation is further complicated by the mismatched expectations of the German and Chinese tax authorities on intercompany financing interest rates, built up from their historical experience. German multinationals that are interested in exploring this cash-pooling mechanism need to consider a number of transfer pricing factors, including the selection of benchmarked markets, identification of opportunity costs, hedging policy and costs, appropriate documentation, as well as the implication of the Chinese thin-capitalisation and German interest limitation rules.

Ulf Andresen (ulf.andresen@de.pwc.com)

Tel: +49 69 9585 3551
Yu Tao (yu.tao@de.pwc.com)

Tel: +49 69 9585 6408

PwC

Website: www.pwc.com

more across site & shared bottom lb ros

More from across our site

There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent
Winston Taylor is expected to launch in May 2026 with more than 1,400 lawyers across the US, UK, Europe, Latin America and the Middle East
They are alleging that leaked tax information ‘unfairly tarnished’ their business operations; in other news, Davis Polk and Eversheds Sutherland made key tax hires
Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’
In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
Gift this article