Treasury Centres are a popular way to organise, process, and book treasury activities. Some treasury centres are global, where they are a located at their head office. Many large companies have regional treasury centres (RTCs) often at three locations to cover each major time zone such as the APAC, EMEA, Americas. In Asia, Singapore and Hong Kong are two popular locations for Treasury Centres. Singapore has a special status for what they call finance and treasury centres (FTCs) and Hong Kong has special tax treatment for what they call corporate treasury centres (CTCs).
In essence, treasury centres exist to centralise and concentrate cash and risk management, as well as talent, and resources to gain economies of scale, process efficiencies, and tighter control. For most companies, tax efficiency is a hygiene factor rather than a primary raison d'etre for treasury centres.
Treasury centres typically operate at multiple levels, such as:
- Transactional: taking intercompany deposits and making intercompany loans, offering intercompany derivatives for hedging, and the resultant transactions with banks to offset net positions,
- Organisational: acting as a centre of excellence, setting policies, and managing bank relationships, and
- Process: running payment factories, netting systems, hedge accounting, and similar processes to capture economies of scale and to ensure process consistency.
Treasury Centres vs Shared Services Centres
Treasury centres are often confused with shared service centres (SSCs). Indeed, many treasury centres are in effect treasury shared services for operating companies. Nonetheless, it is helpful to draw a distinction between treasury centres which are primarily booking centres for treasury transactions and SSCs which are primarily processing operations.
Typically, SSCs focus on high-volume, low value, routine commercial (as opposed to treasury) transactions, which comprise of receivables, payables, accounting, reporting, payroll, fixed assets, etc. Treasury centres, on the other hand, focus on low volume, high value transactions such as loans, deposits, and derivative transactions.
SSCs are typically processing on behalf of operating entities, while treasury centres tend to transact as a principal. For this reason, SSCs do not need to be tax efficient (because they are not processing across their own books), whereas treasury centres need to be tax efficient (because they are booking high value treasury transactions in their own books).
SSCs often seek low labour costs because they require large numbers of talent resources, and SSCs are evolving in the area of process automation over time. Treasury centres typically employ a small number of highly skilled treasury professionals. Therefore, these human resource requirements impact the treasury centre and SSC's location.
In practice, treasury centres normally work very closely with SSCs on the high volume aspects of treasury, such as payments (and the overall procure-to-pay (P2P) process) and collections (and the overall order-to-cash (O2C) process). Some treasury centres actually do commercial payments and collection processing, and thus subsume a part of SSC activities.
Treasury centres often outsource their own processing activities to SSCs. Treasury centres will typically execute loans, deposits, foreign exchange et al., and then rely on their SSC to do the back office activities (confirm, settle, reconcile) and accounting G/L postings.
Treasury Centre vs In-house Banks
The term In-House Bank (IHB) is often used to mean treasury centre, in the sense that a treasury centre acts as an in-house bank where operating entities can makes loans to, take deposits from, and transact foreign exchange with.
IHB also refers to a very specific treasury technique centered around intercompany current accounts and executing flows on behalf of operating entities.
For the sake of clarity, it is preferable to use the term treasury centre when refering to making loans, taking deposits, and transacting foreign exchange with operating entities; and IHB when refering to executing flows on behalf of operating entities and posting them to intercompany current accounts.
It is possible that one treasury team in one location or legal entity does all or a part of the treasury centre, SSC, and IHB's activities. Nonetheless, it is helpful to keep these definitions separate because they refer to distinct and separable activities.
Treasury Centre Activities
Typical treasury centre activities include:
- Intercompany deposits and loans: treasury centres typically concentrate intercompany cash using intercompany deposits and loans - operating entities with excess cash place deposits with the treasury centre who then recycles the deposits into cash (via foreign exchange swaps where necessary) to make intercompany loans to operating entities who are short of cash. As a result, this saves the bank interest margin and balance sheet costs, and this process can be automated with ZBA / Sweeping and or notional pooling
- Foreign exchange: treasury centres typically transact foreign exchange with operating entities with a view to concentrate foreign exchange exposures in the treasury centre, and to minimise the volumes traded with banks and save spreads
- Bank relationships: treasury centres typically manage bank relationships which include arranging banking services and facilities for operating entities, as well as setting up liquidity management and similar arrangements
- Process: treasury centres often facilitate or manage treasury related processes such as payments, collections, hedge accounting, cash flow forecasting
- Policy: treasury centres often set and implement treasury policies and monitor cash balances and flows
Treasury Centre Requirements
The primary requirement for a successful treasury centre is to find experienced treasury talent. Since corporate treasury is a very niche field, such talent is hard to find, and they tend to be concentrated in a handful of locations where treasury centres are located.
Other important requirements for a successful treasury centre include:
- Market access: treasury centres need access to broad and liquid financial markets with a deep pool of support professionals like bankers, lawyers, and other advisors
- Open regulation: since most treasury centres cover multinational operating entities, treasury centres need to be in locations without capital controls and other financial constraints
- Tax: onerous withholding taxes and to a lesser extent high corporate income tax will make treasury centres less cost effective
Treasury centres generally need to work closely with the company's core business, so, once the above requirements have been satisfied, they are often co-located with important business entities such as its global or regional headquarters.
Treasury Centre Organisation
Treasury centres are typically organised into the three classic layers for efficiency and control purposes:
- Front office: interaction with operating entities and market execution (primarily with banks),
- Middle office: process and risk control, and
- Back office: confirmation, settlement, and reconciliation.
Together these three layers will cover the three pillars of treasury: funding, cash management, and risk management.
Since many companies do not have sufficient scale to staff up all these activities within the treasury centre itself, it is common that treasury centres implement a segregation of duties across peer organisations within finance. For example, back office may be undertaken by colleagues in an SSC or in the accounting team, and middle office may be handed to operations control colleagues.
In the case of regional treasury centres, it is common to have shared support functions like middle and back offices globally. Sometimes risk management is globally centralised. Normally, group level funding and capital markets activities are concentrated in one entity, usually at the head office.
Treasury Centre Incentives
Some markets offer special incentives to attract treasury centres, because treasury centres can bring financial flows to the local market and thus contribute to a thriving financial centre.
Most incentive packages include reduced corporate income tax for qualifying activities (typically 50% of the normal CIT rate) and waivers from withholding tax on interest. Some regulated markets offer regulatory waivers to attract treasury centres, but such markets do not normally make good treasury centre locations because regulations like exchange controls inhibit financial markets.
Within Asia, Singapore and Hong Kong are competing fiercely to attract treasury centres.
In summary, both markets have open and deep financial markets, as well as a good infrastructure that is suitable for treasury centres.
The table below compares the two.
|Income tax for TCs||8% on income derived from qualifying services to approved network companies for which at least 3 has to be outside Singapore||8.25% |
on qualifying profits derived from qualifying services provided at least 75% of the assets and profits relate to the qualifying services
|Interest deductibility||Yes||Special provision to allow deduction of off shore interest|
|Withholding tax|| |
in relation to the interest on loans obtained by approved FTC from banks, non-bank institutions and approved network companies outside Singapore provided the funds are used for its approved qualifying services
No withholding tax regime in Hong Kong except for royalties
|Tax treaties||85 as of 2018||40 as of 2018|
|Entity||Legal entity or |
|Talent ||Deep pool||Growing pool|
|Language||Strong English||Strong Chinese|
|Markets||Better for FX||Better for debt|
|Location & focus||Better for APAC||Better for China|
|Number of MNCs||12,000||8,000|
FTCs in Singapore and CTCs in Hong Kong must conduct its transactions with related parties at arm's length and in a commercially justifiable way, as well as maintain contemporaneous transfer pricing documentation unless exempted by laws or regulations.
Another difference between Singapore and Hong Kong is that while Singapore requires explicit approval of FTC status (generally accompanied by certain conditions including headcounts and business spending), Hong Kong grants CTC status on simple compliance with the CTC tax requirements. On the other hand, Hong Kong requires that a new entity be set up with central management and control in Hong Kong and perform actual treasury function in Hong Kong, whereas Singapore can award FTC to the activities of a cost or profit centre of an entity.
Both Singapore and Hong Kong are well connected cities with deep financial markets and good infrastructure suitable for treasury centres. In the end, many companies decide on a location based on their organisational requirements, for example, co-locating with regional headquarters.
Treasury Centre Locations
Generally, treasury centres need locations that are efficient from both tax and regulatory perspectives to act as booking centres for financial transactions. In contrast, SSCs (which are typically processing transactions for other booking centres) look for cheap and abundant clerical labour with practical language skills.
Treasury centre locations in Asia are primarily Singapore and Hong Kong. Singapore has been developing treasury centre capabilities since the early 1990s, giving it a head start over Hong Kong which only started addressing its treasury centre needs in 2016.
Malaysia and Thailand also have treasury centre incentives but, because these are restricted markets with limited treasury talents and less attractive tax incentives, only limited companies have benefited from their offerings.
Other popular treasury centre locations globally include Ireland, Belgium (although Belgium has stopped giving treasury centre incentives), Luxembourg, Netherlands, Switzerland, and Great Britain.
Popular locations in Asia for SSCs include Malaysia and Philippines and India. Some companies have set up in China, because it is such a big market, but it lacks suitable language skills (with the possible exception of Shanghai which is no longer a low-cost location).
To maximise the potential benefits from having a RTC and SSC, many companies capture the benefits of locating its RTC and SSC in different markets that have close proximity. For example, combining a treasury centre in Singapore (legal entity and front office) with support from an SSC in Kuala Lumpur (middle and back office).
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