Reserve income and profit allocation
At year-end, the issuer’s income statement shows the returns earned on reserve investments. Another group company selected counterparties and monitored risk limits; a third now claims a share of the income. Before paying that invoice, the finance team needs to connect the charge to the work performed, the decisions taken and the issuer’s obligations.
This article considers a group with a French company and a European issuer of asset-referenced tokens, or ARTs, subject to Title III of MiCA. It does not cover every product marketed as a stablecoin. E-money tokens and arrangements in other jurisdictions need separate assessments.
Start with the issuer’s obligations
Article 38(4) of MiCA places the profits and losses arising from investment of the reserve, and the resulting counterparty and operational risks, with the ART issuer. The group should therefore not treat that income as a common pool that it can allocate freely.
That provision does not set the price of an intragroup service. Management and support agreements must be assessed against the issuer’s regulatory responsibilities. A service fee needs an identifiable service behind it; a revenue-sharing clause alone does not demonstrate that the proposed transfer is permissible.
Start the file with the token’s classification, the issuer’s identity, investment and delegation agreements, and the people authorised to make decisions. Compliance should assess the arrangement before the tax team prices the work.
Trace the decisions behind the invoice
For cross-border dealings with a related company, the French framework includes Article 57 of the General Tax Code. BOFiP calls for an analysis of functions, risks and resources before choosing a transfer pricing method. Chapter X of the 2022 OECD Guidelines also calls for contracts to be checked against actual conduct and regulatory constraints.
Match invoices to decisions about maturities, counterparties, limits and liquidity needs. Who proposed a change? Who could reject it? Who monitored a breach and initiated corrective action? A formal signature at quarter-end may not describe who did that work.
The OECD’s example of a lender lacking control over risk concerns an advance of funds. It does not automatically turn funds received from ART holders into an intragroup loan. Each flow needs its own characterisation.
Reconciling EUR3 million
Entirely hypothetical case: the issuer records EUR3,000,000 of investment income. External custody and investment charges total EUR200,000. A related French company invoices EUR126,000 for an administrative monitoring service, calculated from EUR120,000 of costs and an illustrative 5% mark-up.
The reconciliation is EUR3,000,000 − EUR200,000 − EUR126,000 = EUR2,674,000. This balance, before other expenses and tax, is neither an established distributable profit nor an amount automatically payable to the parent. The arithmetic validates neither the investments, the delegation nor the transfer price.
Before accepting the EUR126,000 charge, check the service received, the cost base and potential duplicate charges. The 5% is not a demonstrated market rate. If the French team also makes investment decisions, reconsider the administrative agreement and pricing method. Adding a percentage would not resolve that mismatch.
A file that supports the closing decision
BECTRA can structure the file around an entity-by-entity reconciliation of reserve income, external expenses, related-party charges and the remaining result. Each invoice links to the agreement, work delivered, decisions observed and support for its price.
The closing note separates three decisions: accept a documented service charge, request missing evidence or revisit the arrangement with tax and compliance. It records outstanding questions, an owner and a response date. Separate-company accounts, consolidation and any dividend distribution require distinct assessments.
Conclusion
To approve an intragroup charge against reserve income, management needs to trace it back to the work performed and the price selected. The reconciliation helps identify unexplained transfers. It must remain consistent with the ART issuer’s obligations and the arm’s length conditions relevant to the French company.
Further reading
Sources
Texts reviewed on 3 November 2026. Scope: a French company and a European ART issuer. Hypothetical numerical case; reconciliation approach: BECTRA analysis.
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