This guidance note provides an overview of cross-border 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 the potential tax issues, see the Cash pooling ― potential tax issues guidance note.
A cross-border cash pool can be more complicated to arrange than a domestic one, as the potential members tend to have accounts with different local banks that cannot be linked together in a pooling arrangement. It is not uncommon for a completely new set of bank accounts to be opened to facilitate a cross-border pool.
With the continued growth in global business, groups face increasing pressure to manage the cash and liquidity requirements of neighbouring subsidiaries on a short-term basis without the formality of repatriating profits and advancing structural loans. Cash pooling is an ideal way of achieving this. The downside is that it requires the regular transfer of funds between accounts
Timing of disposal for capital gains taxDate of disposalThe date of the disposal determines the period in which the gain is subject to capital gains tax (CGT). When the rates of CGT change, the determination of the date of disposal can also affect the rate of CGT that applies to the gain.See the
Foreign self-employmentTrading in another jurisdiction involves many issues, only some of which involve taxation. Advice should be taken, not only in relation to tax but on the wider business implications. For an overview of the points to consider for certain jurisdictions see Tolley's Global
Capital allowances on carsSummary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions of 50g/km and below 18%CAA 2001, s 104AASecondhand cars with CO2