On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm’s-length principle and the methodologies for evaluating the arm’s-length nature of transactions between related companies.
The Q&A guidance offers analysis and insights on applying transfer pricing principles in Switzerland. It also provides further clarification on reinforcing the use of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. It also provides practical examples of specific methods, comparability analysis, and how to handle financial transactions and adjustments within Swiss tax law. This guidance also explains specific issues and assists companies in meeting transfer pricing regulations, underscoring the significance of complying with the arm’s-length principle to ensure fair taxation of cross-border intra-group transactions.
On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide.
