SSK / SFTA Article On Transfer Pricing

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.

On 23 January 2024, the Swiss Tax Conference ("SSK"), in cooperation with the Swiss Federal Tax Administration ("SFTA"), published a detailed "article" on the topic of transfer pricing for the tax information dossier for the first time. The article covers the arm's length principle, the comparability analysis of transfer prices and the various methods for determining transfer prices. In addition, procedural aspects in connection with transfer pricing are outlined. The article published by the SSK and the SFTA is limited to the treatment of income tax and withholding tax.