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BangladeshIndia
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Corridors we are building first
India ↔ United Arab Emirates A regional hub in the UAEIndia ↔ Saudi Arabia A Saudi entity for government workUAE ↔ United Kingdom A UK subsidiary
24 corridors
India ↔ United Arab EmiratesIndia ↔ Saudi ArabiaChina ↔ Southeast AsiaUnited Kingdom ↔ GCCGermany ↔ GCCUnited States ↔ MexicoUnited States ↔ Latin AmericaEurope ↔ AfricaJapan ↔ Southeast AsiaSingapore ↔ IndiaGCC ↔ AfricaChina ↔ AfricaChina ↔ GCCIndia ↔ AfricaEurope ↔ IndiaNordics ↔ GCCSouth Korea ↔ GCCUnited States ↔ BrazilUnited States ↔ Caribbean & Central AmericaAustralia ↔ Southeast AsiaUAE ↔ EuropeUAE ↔ United KingdomSaudi Arabia ↔ United StatesIndia ↔ United States
Disputes · UNIONE™

Before the dispute. Beyond the award.

When cross-border business becomes a dispute, UNIONE™, also part of the UNBOUNDED™ Global Ecosystem, prevents it, resolves it, arbitrates it and plans enforcement. 334 Fellows in 58 countries.

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01 · Before signatureBefore You Sign™Get the dispute clause, governing law, seat, notices and escalation steps right while the contract can still change.02 · A dispute is emergingBefore You Arbitrate™Test the claim or the defence, the evidence, the exposure and the settlement options before committing to formal proceedings.03 · A binding decision is neededArbitrationStart, answer or run an administered arbitration under the UNIONE™ Rules, with procedure sized to the value, urgency and evidence.04 · Before enforcementBefore You Enforce™Plan recognition, assets, jurisdiction and security, including State and State-owned parties, before committing to enforcement.
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Cases · Capital & assets · Payments, FX, digital assets & treasury

Set up intercompany funding

How do we set up loans between our group companies abroad?

WONE Global drafts the agreements, sets arm's-length terms and checks withholding, thin-capitalisation and registration rules in each country.

Bring a requirement →Ask WONE first

Countries in the typical case Netherlands · Germany · Spain · Poland · Türkiye · South Africa

The situation

What is happening

What is at stake

Intercompany loans without proper terms are challenged by tax authorities and blocked by banks.

A scenario

Holding companyCorporation · from Netherlands · in Germany, Spain, Poland and 2 more

It lends to subsidiaries in five countries without written agreements.

Where it ends Loans tax authorities will accept.

A representative scenario of the work WONE Global coordinates, not a specific client’s matter.

Also asked as “Intercompany loan agreement”“Transfer pricing for intercompany loans”“We need to review cross-border intercompany loans”

The solution

How WONE Global handles it

WONE Global drafts the agreements, sets arm's-length terms and checks withholding, thin-capitalisation and registration rules in each country.

Usually led by Tax & International Structuring, with Finance & Treasury and Legal & Contracting.

Step by step, in the scenario

  1. Week 1WONE Global reviews each loan.
  2. Week 2Arm’s-length terms set.
  3. Week 3Agreements signed and registered where needed.
  4. ThenAnnual review.

Timings are typical. They depend on the countries, the authorities involved and how quickly documents are available.

Decisions

The decisions involved

  1. 01Arm's-length interest and terms
  2. 02Interest-deductibility limits in each country
  3. 03Cash pooling or bilateral loans

Outcomes

What you receive

  • Intercompany loan agreements
  • Transfer-pricing support for the terms
  • A funding policy for the group

This is a general guide. Your WONE Global professional confirms the work, timing and fees for your markets before anything starts.

Services

The services involved

One area of expertise usually leads; the others move with it. WONE Global keeps them connected across every country involved.

  1. Usually leadsTax & International Structuring25 markets with a named lead→
  2. Often involvedFinance & Treasury2 markets with a named lead→
  3. Often involvedLegal & Contracting18 markets with a named lead→

Who handles it

Tax & International Structuring, market by market

The status of the lead service in the markets that matter for this case. A named WONE Global Partner acts under their own licence; where none is in place yet, WONE Global confirms availability before anything else.

  1. Germanyin the typical case WONE Global Partner Ulrike Berner, MBA · Managing Partner Brief this Partner →
  2. South Africain the typical case WONE Global Partner Johan Beer · Partner Brief this Partner →
  3. Spainin the typical case WONE Global Partner Darragh Brady · Partner CIB Finance Brief this Partner →
  4. Netherlandsin the typical case On request Availability confirmed before any work begins Bring a requirement →
  5. Polandin the typical case On request Availability confirmed before any work begins Bring a requirement →
  6. Türkiyein the typical case On request Availability confirmed before any work begins Bring a requirement →
  7. Austria WONE Global Partner Dr. Rosam Karl J. · Managing Director Brief this Partner →
  8. Bolivia WONE Global Partner Andres Fernando Uria Palma · Managing Partner Brief this Partner →
  9. Cameroon WONE Global Partner Edmond Christian AKOA MBALLA · Founder & Managing Partner Brief this Partner →
  10. Canada WONE Global Partner Peter S. Johnson · Tax Partner Brief this Partner →
  11. Colombia WONE Global Partner James Tamayo Puerta · Managing Partner Brief this Partner →
  12. Cyprus WONE Global Partner Angelo Aristodimou · Managing Director Brief this Partner →
  13. Ecuador WONE Global Partner Mauro Tejada Ramon · Tax & Legal Partner Brief this Partner →
  14. Hong Kong WONE Global Partner Yvonne Chow · Partner Brief this Partner →
  15. India WONE Global Partner Bhavik Bhanushali · Managing Partner Brief this Partner →
  16. Iraq WONE Global Partner salah mawlood obaid · alkhateeb Brief this Partner →
  17. Ireland WONE Global Partner Kevin McSharry · Managing Director Brief this Partner →
  18. Italy WONE Global Partner Francesco Mangiameli · Founding & Managing Partner Brief this Partner →
  19. Kenya WONE Global Partner Abdul Bagha · Managing Partner Brief this Partner →
  20. Libya WONE Global Partner Dr. Mohamed Fawzi Kurd · Chairman & Managing Partner Brief this Partner →
  21. Morocco WONE Global Partner Mouad Aktaou · Managing Partner Brief this Partner →
  22. Panama WONE Global Partner Ebrahim Asvat K. · Managing Partner Brief this Partner →
  23. Portugal WONE Global Partner Hugo Ribeiro · Owner Brief this Partner →
  24. Rwanda WONE Global Partner Lilianne Gasango · Tax & Financial Advisor Brief this Partner →
  25. Saudi Arabia WONE Global Partner Abdullah Yousef Alhussaini · Founding Partner Brief this Partner →
  26. Switzerland WONE Global Partner Michael Sterchi · Founder Brief this Partner →
  27. United Arab Emirates WONE Global Partner Sunil Thomas · Partner & Auditor Certificate Holder Brief this Partner →
  28. Zambia WONE Global Partner Gerald Zimba · Director Brief this Partner →
  29. Singapore On request Availability confirmed before any work begins Bring a requirement →
  30. United Kingdom On request Availability confirmed before any work begins Bring a requirement →
  31. United States On request Availability confirmed before any work begins Bring a requirement →

Other markets: WONE Global covers 100 countries. Name yours in the requirement →

Angelo AristodimouNicosia · Cyprus

WONE Global Partner · Cyprus

Angelo Aristodimou

Managing Director · McMillan Woods Cyprus Ltd · Nicosia

Experienced finance professional with a proven track record in the finance industry. Expertise includes audit, accounting, financial planning, internal controls, tax planning, company formation, and corporate structurin…

Send Angelo your requirement →

Discover

Where this case connects

The markets, corridors and guides behind this case, and the questions to put to Ask WONE below. Every link opens a page that links back here.

Worked examples

How it goes in practice

Researched corridor journeys, and representative scenarios on the same subject. None is a specific client’s matter.

Payments, FX, digital assets & treasury

Related cases

All 17 cases on this subject →
Urgent Our bank has frozen an international payment. What can we do?Urgent We paid a fake invoice to a fraudster's account abroad. Can we get it back?Urgent Tax was deducted abroad and again at home. Can we get it back?How do we pay overseas suppliers safely and cheaply?How do we move cash between our companies in different countries?Our international payments keep getting delayed or rejected. Why?How do we protect ourselves from currency swings?How do we bring profits back from our company abroad?How do we bring cash and assets home when closing abroad?Currency swings are eating our margins. How do we protect ourselves?

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