Transfer pricing3 credits

Pool rates per participant — substantiated and reproducible

Calculate an arm’s length rate for every participant in your group cash pool: a synthetic rating from their own key financials, a credit margin with full premium decomposition and the 1-year swap curve in the pool currency — with a certified report stating every intermediate step and every dataset used.

cash-pool v1.0.0 · vintage 2026.1 · draft free
Example outcome
Participant rate — credit position (Aaa)3.7888%
Risk-free base — 1Y EUR swap (2024)3.2100%
Credit margin — Aaa, senior unsecured0.5788%
Pool net position (credit − debit)€ 2,000,000
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01Group treasurers running an in-house bank or cash pool who must recalibrate participant rates each year.
02Transfer pricing specialists documenting the remuneration of pool participants in the local file, substantiated per entity.
03Controllers of participating operating companies who book intercompany interest per entity and must justify it to their auditor.

What the tool does

✓ Synthetic credit rating per participant, from their own key financials✓ Rate = 1-year swap curve in the pool currency (EUR, USD, GBP) plus credit margin, transaction years 2021–2026✓ Premium decomposition per participant: expected loss, regulatory, market and operational risk✓ Industry and country per participant; the pool leader’s country drives the risk-free rate, ERP and tax rate✓ Pool totals: total credit position, total debit position and net position✓ Flagging above the 12% threshold (art. 8b Dutch CIT Act 1969) and testing of the pool manager margin against the OECD range (§10.136–10.141)✓ Certified PDF with every intermediate step, tool version and the dataset vintages used
01 — Form
Case and key figures — a handful of fields.
02 — Draft
Full outcome layout, free.
03 — Pay and receive
Via Mollie, VAT/VIES handled.
04 — Report
Certified PDF + public hash.

Why cash pool rates are rarely properly substantiated

For tax purposes a cash pool is not one transaction but a series: every participant takes its own position and must receive or pay its own arm’s length remuneration. In practice groups apply a single pool rate to everyone — exactly where the inspector probes: why does a weak operating company pay the same as a strong one?

Jurical prices every participant separately and records the route: the rating from the key financials, the build-up of the margin, the swap curve used and the dataset vintage. Every report carries the tool version and a cryptographic hash, so the same input yields the same document years later.

Frequently asked questions about this tool

How is each participant’s rate built up?
The 1-year swap rate in the pool currency plus a credit margin derived from the participant’s synthetic rating, industry and country. If the swap rate is negative the result is floored at 0%; the report flags this explicitly.
Does the pool type change the outcome?
Not for the participant rates: those always price off the 1-year swap curve (OECD §10.133), whatever the pool type. The pool type does determine the reference range for the pool manager margin: notional pooling 10–30 basis points, zero-balance 25–50 basis points. The report tests the pool manager’s gross spread against that range.
Does the tool allocate the pool benefit across participants?
No. Every participant is priced standalone; credit and debit positions follow the same formula. Allocating the synergy benefit and remunerating the pool leader are separate, highly fact-dependent judgements that you substantiate yourself alongside this calculation.
Try the draft — free and without an account.
You pay only when you unlock the report.
Start the calculation

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Pool rates per participant — substantiated and reproducible — Jurical