Practice Summary On Swiss Transfer Pricing Published

On 23 January 2024, the Swiss Tax Conference (Schweizerische Steuerkonferenz) (SSK) published its first comprehensive paper on transfer pricing (the TP Paper). The publication marks the first comprehensive transfer pricing publication by the Swiss Federal Tax Administration (SFTA) and all cantonal tax administrations.

Applicable to Swiss taxpayers in cross-border constellations, the TP Paper is a clear confirmation that proper transfer pricing analysis and documentation is increasingly important.

Background

The TP Paper was published by the SSK, i.e., an association of the 26 cantonal tax authorities jointly with the SFTA. It is therefore important to note that the publication is supported by all Swiss tax administrations, showing that transfer pricing is one of the most important topics at the moment.