Spanish Supreme Court Rules on Transfer Pricing for Cash Pooling Arrangement

The Spanish Supreme Court recently published Judgment No. 3721/2025 of 15 July 2025, which concerns the transfer pricing treatment of a cash pooling arrangement involving a Spanish subsidiary of a multinational group during the 2014 and 2015 tax years. The subsidiary participated in a daily cash sweep system managed by a cash pool leader established in the Netherlands, which received funds at one interest rate and lent them out at another (asymmetrical rates). The rates were determined based…