State of Play of Intra-Group Financing Arrangements

The author provides an overview of intra-group financing arrangements from a corporate, tax and accounting perspective. It also discusses the treatment of interest-free loans from the perspective of both the tax authorities and the Supreme Court and considers the characterization by Italian courts of cash pooling arrangements – including their possible recasting as intra-group loans.


Intra-group financing arrangements represent, for multinational groups, useful instruments to manage debt and liquid assets in an efficient manner. Given its importance for both national and foreign investors, this article will provide an overview – from a corporate, tax and accounting perspective – of intra-group loans in Italy, also focusing on the treatment of interest-free loans, from the perspective of both the tax authorities and the Supreme Court. The main issues surrounding intra-group interest-free loans is the application (or not) of ...

Discover the full article - first published on IBFD (issue no. 4, vol. 19, July/August 2017).

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