On 29 and 30 January 2024, the Swiss Federal Tax Administration (SFTA) published the safe harbour interest rates for the year 2024. The rates apply to intra-group loans denominated in Swiss Francs and foreign currencies as of 1 January 2024.

The SSK and the SFTA have for the first time published a comprehensive article on the topic of "transfer pricing". Below you will find a brief overview.

After publishing a summary on transfer pricing rules in Switzerland (TP Paper), the SFTA has now published a website notably including a rather extensive Q&A on selected Swiss transfer pricing topics.

Switzerland's position as a leading global commodities trading hub is reinforced by competitive cantonal tax rates, efficient infrastructure, and a favourable regulatory environment.

On 27 and 28 January 2025, the Swiss Federal Tax Administration (SFTA) published the safe harbour interest rates for the year 2025.

Nach der Ablehnung des Entwurfs zum Unternehmenssteuerreformgesetz III („USR III-Entwurf `) in der Volksabstimmung v 12.2.2017 (vgl. Schreiber/Diefenbacher IStR-LB 2017, 35 ff.)

The amount of outbound and inbound M&A transactions continued to grow in 2018. The record-breaking 493 transactions involving Swiss companies and investors were reported

Switzerland is one of the most attractive business locations globally, thanks to its stable economy, clear legal frameworks, and significant tax advantages.

Switzerland will introduce the international spontaneous exchange of information in tax matters into domestic legislation on the basis of the signed Convention on the MAC.

The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.

Im zweiten Teil der Beitragsreihe "Daten in Rechnungslegung und Steuerrecht" erfolgt ein vertiefter Blick auf die strategischen und informationstechnologischen Aspekte...

Als Fundament für die weiterführenden Überlegungen wird im ersten Teil dieser Beitragsreihe auf verschiedene Begriffe im Kontext Big Data eingegangen,...

On 23 January 2024, the Swiss Tax Conference (Schweizerische Steuerkonferenz) (SSK) published its first comprehensive paper on transfer pricing (the TP Paper).

The 2013 OECD's Base Erosion and Profit Shifting (BEPS) initiative was aimed at combatting tax abusive and aggressive tax structures.

Transfer pricing, the pricing of goods, services, and intangibles between related entities, has always been a significant concern for multinational enterprises...

Switzerland moves towards the spontaneous exchange of information on tax rulings to play its part in the OECD BEPS project.

Article 1.2 of the Model Rules establishes the definitions of MNE Group and Group. The first definition of MNE Group is set forth in Article 1.2.1, according to which an MNE Group means ...

In an international context, Switzerland is considered an attractive business location, not least due to the Swiss tax system.

The term "big data" has been in use since the early 1990s. Thus, big data is not something that is completely new. What has changed within the last three decades, however,...