Together with the SSK, the FTA has prepared a new article "Transfer pricing" for the tax information dossier and published it on January 23, 2024.
The article deals with the arm's length principle in Swiss tax law in cross-border relationships. It primarily refers to the 2022 version of the OECD Transfer Pricing Guidelines and addresses the topics of comparability analysis, transfer pricing methods, intangible assets, intra-group services, financial transactions, documentation and procedural aspects.
The document is available here.
