Switzerland transfer pricing documentation guide
July 14, 2009
Norbert Raschle, Nicolas Bonvin and Mohamed Serokh, PricewaterhouseCoopers
Switzerland has no plans to issue any specific domestic provisions on transfer pricing in the near future. There is, however, an increasing awareness of the issue and concern on the part of the Swiss tax authorities that taxpayers may transfer profits without economic justification to countries with strict transfer pricing rules and documentation requirements in order to avoid challenges by the respective local tax authorities. In this context Swiss tax authorities take an increasing interest in a company’s transfer pricing position in order to secure its own tax base. In addition, some cantonal (regional) tax authorities have begun to particularly focus on low risk/low profit entities located in Switzerland.
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