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HMRC internal manual

International Manual

Intra-group funding: group finance companies and the treasury function: Introduction

Overview

The terms “treasury company” and “group finance company” can cover a wide range of activities, from a simple conduit through which funds flow, to a company with a complex range of activities. The approach to determining the appropriate arm’s length price for the functions undertaken and transactions performed by treasury and group finance companies is no different from other transfer pricing enquiries, in that it requires the application of an authorised OECD approach (see INTM463000).

The terms treasury company and finance company can be interchangeable so it would be unwise to make assumptions about risks and functions based on how the company is labelled. For the sake of clarity this guidance only uses the name treasury company for businesses which perform the more complex money management functions and assume the associated risks. The name group finance companies will generally be used to describe more straightforward operations usually built around the funding of the group, including conduits (see INTM503020). Larger groups may include examples of both.