Primary, Corresponding and Secondary Transfer Pricing Adjustments

In recent years, Swiss tax authorities, both federal and cantonal, have placed increasing emphasis on transfer pricing issues. They have deployed growing resources to carry out transfer pricing-related tax audits, thereby expanding the number of primary and secondary adjustments affecting Swiss taxpayers. At the same time, the number of mutual agreement procedures involving Switzerland in the field of transfer pricing has also risen. The purpose of this article is to provide a comprehensive, in-depth view of the Swiss legal framework in the field of transfer pricing adjustments and its application by the Swiss authorities, particularly in light of the most recent developments in this area, focusing solely on corporate income tax and withholding tax.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2024-08-13
DOI
https://doi.org/10.59403/39qk88j
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Primary, Corresponding and Secondary Transfer Pricing Adjustments

N. Burkhalter-Martinez, J. Roy-Stämpfli
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Primary, Corresponding and Secondary Transfer Pricing Adjustments

N. Burkhalter-Martinez, J. Roy-Stämpfli
article en

Abstract

In recent years, Swiss tax authorities, both federal and cantonal, have placed increasing emphasis on transfer pricing issues. They have deployed growing resources to carry out transfer pricing-related tax audits, thereby expanding the number of primary and secondary adjustments affecting Swiss taxpayers. At the same time, the number of mutual agreement procedures involving Switzerland in the field of transfer pricing has also risen. The purpose of this article is to provide a comprehensive, in-depth view of the Swiss legal framework in the field of transfer pricing adjustments and its application by the Swiss authorities, particularly in light of the most recent developments in this area, focusing solely on corporate income tax and withholding tax.

International Transfer Pricing JournalVol. 31(5)
Openalex Percentile: Top 80%
Corporate Taxation and Avoidance
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Primary, Corresponding and Secondary Transfer Pricing Adjustments — N. Burkhalter-Martinez, J. Roy-Stämpfli · International Transfer Pricing Journal (2024) | TGRS Research Map | TGRS