Introduction to Transfer Pricing

Transfer pricing is a critical aspect of international taxation that involves setting prices for transactions between associated enterprises, their shareholders and other related parties. Properly managing transfer pricing ensures compliance with tax regulations and prevents recapture of taxable profit and penalties from tax authorities.

New guidelines on Transfer Pricing in Switzerland

On February 23, 2024, the Federal Tax Authorities (FTA) of Switzerland published new guidelines on transfer pricing. This publication marks another step in Switzerland’s ongoing efforts to align its tax regulations with the OECD guidelines, reaffirming its commitment to international standards and transparency.

Our Expertise in Transfer Pricing

At Axcord SA, we have been actively engaged in negotiating advance tax rulings based on OECD principles with the FTA well before the official publication of these new guidelines. Our proactive approach ensures that our clients benefit from rulings that are fully compliant with international regulations. These rulings provide taxpayers with clear principles of taxation in Switzerland, ensuring that their activities are aligned with local and international tax requirements.

Benefits of advance tax rulings

The advance tax rulings on Transfer Pricing we negotiate offer several key benefits:

• Taxpayers receive a clear understanding of their tax obligations in Switzerland, reducing the risk of disputes with tax authorities.
• Ensuring compliance with international regulations minimizes the risk of penalties and reputational damage.
• Businesses can plan their operations more effectively, knowing that their transfer pricing strategies are approved by the FTA.

Special Provisions for Limited Presence and Substance

For taxpayers with a limited presence and substance in Switzerland, it is possible to negotiate transfer pricing principles that provide for a minimum margin in Switzerland. This approach allows companies to maintain compliance without overstating their economic activities or presence in Switzerland.

Why Choose Us?

Our team of experts has extensive experience in international tax and transfer pricing. We offer tailored solutions that meet the unique needs of each client, ensuring compliance and optimizing tax positions. By partnering with us, you gain:

Expert Negotiation
Leveraging our deep understanding of Swiss tax laws and OECD guidelines, we negotiate favorable terms with the FTA.

Comprehensive Support
From initial assessment to the final ruling, we provide end-to-end support, ensuring a smooth and efficient process.

Global Perspective
Our international experience ensures that your transfer pricing strategy is aligned with global best practices.

Contact Us

To learn more about our transfer pricing services and how we can assist you in navigating the new guidelines, please contact us at contact@axcord.com.