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This guidance note provides an overview of tax issues which can arise when companies use cash pooling. For an overview of cash pooling and the different types of cash pool, see the Cash pooling ― overview guidance note. For a discussion of additional points that need to be considered for a cross-border cash pool, see the Cash pooling ― cross-border considerations guidance note.

Tax considerations rarely affect domestic pooling arrangements but can be a significant factor in a cross-border structure.

It is widely recognised that legal and regulatory rules can prevent a group from implementing its supposedly ideal structure. It is not unusual for an evaluation of the tax issues to be overlooked until after a structure has been agreed with the bank. In some cases, the tax implications may not even be considered until after the structure is operational.

However, international tax rules can give rise to costs and liabilities that can reduce, or even eliminate, the financial savings expected from the preferred commercial structure. Although tax is unlikely to prevent a group from