TRANSFER PRICING: Utilising the benefits of a low tax environment to implement transfer pricing related planning structures

The implementation of some transfer pricing structures allows benefiting from the moderate level of income tax in Switzerland. Protecting such benefits to the extent possible against attack by foreign tax authorities goes hand in hand with developing necessary transfer pricing analysis and documentation. One of these potentially beneficial transfer pricing structures is described in further detail below, namely: The Swiss Business Control Centre (BCC) structure.

BCC (Business Control Centre concept)

The starting point of the implementation of the Business Control Centre (hereafter BCC) structure is the allocation of profits consistent with world-wide operating strategies thereby allowing an optimisation of the group tax structure. More and more businesses attempt to centralise regional or world-wide management responsibilities and other core functions in headquarters or shared service centres located in tax friendly jurisdictions and at the same time introduce centralised supply