Transfer pricing rules

According to Swiss tax law, transactions between group companies must be at arm’s length. Switzerland does not have a separate transfer pricing legislation and does not plan to enact such legislation in the near future. Instead, the Swiss tax authorities follow the transfer pricing guidelines of the OECD to determine if a transaction between related parties is at arm’s length. In Switzerland, no specific documentation requirements for transfer pricing purposes must be observed. A company doing business in Switzerland should however have the appropriate documentation on file verifying the arm’s-length nature of transactions with related parties.