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BEPS and its impact on Corporate Treasury
| 25-01-2018 | treasuryXL |
Impact
Many large companies have developed funding and cash distribution strategies around tax regulations. The Netherlands is specifically known for its activity in Trust Offices. The changes envisaged by BEPS could result in the corporate structure of a company being deemed invalid. Many large international companies have Dutch registered offices whilst no physical work is done within the Netherlands.
It is not uncommon to see intercompany financing being structured purely to avail itself to the current tax regimes and advantages within different countries. Interest is a cost and is deductible against tax in many places. Structures have been put into place where a company arranges for interest to be paid at a company within a high tax regime, whilst the interest is received in a country with a low tax regime. BEPS has been designed to tackle this sort of situation.
Companies will now have to submit detailed reports on their holdings and representations on a country by country basis. Such reports will assist the tax authorities in better understanding how the global operations of a company are performed. This should lead to greater clarity on the transfer pricing policy being used by companies.
Companies need to review and outline their existing structures and investigate what the changes and impact will be once BEPS is initiated. It is quite conceivable that certain operations will be seen as not meeting the new criteria – leading to a change in the existing company strategy. This could lead to disadvantageous results, such as increases in the weighted average cost of capital that a company reports, which could affect its share price.
This means action has to be undertaken and this could lead to significant changes within some treasury departments.
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Blockchain and payments: further on the Gartner Hype cycle?
| 24-01-2018 | Carlo de Meijer |
Last month Blockchain bank consortium R3CEV and 22 of its partners announced that they were collaborating on the development of a cross border payments platform built using distributed ledger technology. This may be the first time a shared infrastructure has been developed that addresses the full payment workforce.
The question is: where are we now in the Gartner cycle, and will this R3 initiative be the breakthrough for a more massive adoption of this technology in the payments area?
Central banks: still see hurdles
Also central banks are actively investigating and in some cases even experimenting with blockchain including those of the United States, Canada, China, U.K., France, Germany, the Netherlands, Singapore, South Africa, and Sweden. Central banks’ interest in blockchain represents further recognition of the technology’s potential to transform many aspects of financial systems worldwide, including international payments. They are generally positive about the technology’s potential for applications such as international payment solutions.
On the other hand central banks also note technical obstacles such as scalability and other concerns such as privacy, security and legal issues. They generally emphasize that the technology is still at an early stage and may be years away from widespread use for such applications.
In a recent published research paper, the Deutsche Bundesbank offers up some encouragement for DLT acceptance. They are highlighting the technology’s ability to eliminate reconciliation processes, boost transparency and protect against cyber-attacks. The Bundesbank however dampened the blockchain enthusiasm, dismissing distributed ledger technology’s prospects in retail payments, at least in the Eurozone, which already boasts fast transfers and systems that require a minimum of reconciliation and can process millions of transactions with ease every day.
The authors concede that “it is still unclear whether DLT also has the edge over today’s technology in terms of security, efficiency, costs and speed”.
Read the full article of our expert Carlo de Meijer on Finextra
Carlo de Meijer
Economist and researcher
What will be the new “normal” for interest rates?
| 23-01-2018 | Lionel Pavey |
From a high of just over 5% in the summer of 2008, 10 year swap rates have fallen to a low of around 0.25% in the autumn of 2016 and are currently just under 1%. Historically, it has been usual to describe prices as moving back to around the average. However, having just under 20 years of data, it is possible to analyse the average fairly quickly.
The average rate for 10 year swaps for the last year is about 0.80%
The average rate for 10 year swaps for the last 2 years is about 0.70%
The average rate for 10 years swaps for the last 5 years is about 1.15%
The average rate for 10 year swap for the last 10 years is about 2.20%
And the average since 1999 when the Euro started is about 3.40%
The lowest rate was about 0.25% in 2016
The highest rate was about 6% in 2000
What is normal? From a personal point of view when I took out my first mortgage (back in the previous millennium) the advice I was given was that if long term fixed rates (10 years) were lower than 6.5% I should look to lock into that rate as the long term average was 7%. With every other property that I subsequently bought the long term fixed rates were lower than with my first mortgage. Currently mortgage rates for 10 year fixed are around 1.75%. Long term interest rates have been steadily falling for the last 30 – 35 years.
So, when we talk about rates eventually rising, we are still left with the problem that previous benchmarks – which were normal then – may not be applicable anymore.
A rate raise is absolute – the magnitude and its impact will be relative to our perception of the new “normal” benchmark.
Lionel Pavey
Cash Management and Treasury Specialist