Cash pooling and centralised stablecoin treasury
A group pooling stablecoins must explain the debt created between its companies, who bears a loss and why each participant accepts the proposed terms. Fast token transfers answer none of these questions. For a French subsidiary, the decision starts with a cash forecast and an intercompany agreement, before choosing a wallet.
Identify the transaction before pricing it
The OECD guidance distinguishes physical concentration from notional pooling. It calls for an assessment of actual functions and risks, each member's available alternatives and the allocation of group benefits. A persistent balance may be a term loan rather than short-term liquidity. The pool leader's reward depends on what it actually does; coordination alone does not automatically warrant a bank-like spread. [S1]
On a blockchain, the observable event is a transfer between addresses. It does not establish whether the recipient owes euros, a fixed number of tokens or a custody service. Our recommendation is to prepare a record for each flow: debtor, creditor, denomination, maturity, withdrawal rights and the consequences of suspended redemption. This is a BECTRA working method, not an OECD classification expressly applicable to every stablecoin.
Worked example: a EUR 1,000 saving can fall to EUR 550
Consider a hypothetical group with a French industrial subsidiary and a treasury centre abroad. Over 30 days, one company needs EUR 600,000 while another has EUR 400,000 available. To isolate the pooling effect, all flows are in euros. The 5% borrowing and 2% deposit rates are teaching assumptions, not market benchmarks. Interest uses an illustrative 360-day year.
Calculation over 30 days | Amount |
|---|---|
Standalone borrowing: 600,000 × 5% × 30/360 | EUR 2,500.00 |
Standalone deposit: 400,000 × 2% × 30/360 | EUR 666.67 |
Net cost without pooling | EUR 1,833.33 |
Residual funding: 200,000 × 5% × 30/360 | EUR 833.33 |
Gross pooling saving | EUR 1,000.00 |
Additional coordination, custody and conversion costs | EUR 450.00 |
Saving available after these costs | EUR 550.00 |
This calculation assumes that the EUR 400,000 can legally and operationally be mobilised. It excludes tax and default events. If the group transfers value through stablecoins, it must then quantify network fees, conversion spreads and the ability to redeem into euros. An advertised peg is not a guaranteed bank receipt.
The CFO should not assign the EUR 550 to the treasury centre by default. Prepare a comparison for each participant: standalone cost, pooled cost, service charges and retained risks. If the depositing company gives up daily access, a rate-only comparison is incomplete. A 1% redemption loss on the EUR 400,000 mobilised would be EUR 4,000, more than seven times the calculated net saving. This sensitivity is neither a default probability nor a forecast.
French subsidiary: pricing and legal permission need separate reviews
Article 57 of the French tax code allows adjustments for indirectly transferred profits in cross-border dealings between dependent enterprises; the French tax administration explains the framework in its guidance. The French subsidiary should therefore retain support for its intercompany terms. This does not supply a standard stablecoin pooling rate. [S2]
Article L. 511-7(I)(3) of the French Monetary and Financial Code provides an exception for certain treasury transactions between companies linked by capital relationships conferring effective control. Checking those conditions is separate from the tax analysis. That provision alone does not classify the tokens or validate the contemplated custody and payment services. The actual structure and each participating jurisdiction require their own review. [S3]
The subsidiary's file should identify who approves limits, evidence of address control, daily statements, reconciliation to intercompany accounts and exit conditions. A recurring debit balance should trigger a review of duration and funding. Daily sweeping does not automatically make a structural funding requirement temporary.
What the treasury committee should receive
The useful deliverable is a decision file containing a flow map, a responsibility matrix, a net-benefit simulation by participant and an agreement consistent with actual conduct. BECTRA can structure this file and the transfer pricing analysis; tax and regulatory conclusions depend on countries, contracts and available evidence. The committee can then choose between a limited pilot, revised terms and the existing banking route.
Conclusion
A stablecoin cash pool needs a demonstrated benefit for its participants and a documented allocation of risks. Before transferring tokens, the French subsidiary must know its claim, its return and its redemption route. In this example, the decision concerns a EUR 550 net saving, not transfer speed alone.
Further reading
Sources
Sources reviewed on 26 October 2026. Matrices, examples and calculations are BECTRA analysis; cases are hypothetical.
[S1] OECD, Transfer Pricing Guidelines, 2022, Chapter X, paragraphs 10.109–10.147, especially 10.118, 10.122 and 10.129–10.137. — Read the source
[S2] French tax administration, BOI-BIC-BASE-80-20, published 10 December 2025, commentary on Article 57. — Read the source
[S3] Légifrance, French Monetary and Financial Code, Article L. 511-7, version applicable on 26 October 2026. — Read the source
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