Transfer pricing
Here you will find the most important information on transfer pricing. Transfer pricing refers to the prices and other conditions applied to cross-border transactions between companies that are legally independent but belong to the same group. Transfer prices must comply with the arm's length principle, according to which transactions between these companies should be conducted on the same terms as would be agreed upon between independent companies.
General information on transfer pricing
Questions and answers on transfer pricing
OECD Transfer Pricing Guidelines
Directly to OECD
Cost plus method
The cost plus method is based on the costs incurred by the provider of goods or services in an intra-group transaction, to which a mark-up is added.
Treatment of taxes in the cost base in the context of the cost plus method
Federal Statement on judgement of the Supreme Court judgement 9C_37/2023 of 11 June 2024
Primary, corresponding and secondary adjustment
Withholding tax in the context of primary, corresponding and secondary adjustments.
Cost sharing arrangement
Tax implications for Swiss taxpayers of Altera vs. Commissioner decision of the US Tax Court of 7 June 2019
Intra-group loans
An intra-group loan must be granted on terms that would have been negotiated by independent companies.
Publication
News
Course listings (ICTax)
The Federal Tax Administration has updated the course listings and bonus shares 2024, 2025 and 2026.
New FTA portal
From 11 May, the FTA portal will bring together numerous FTA online services in a single overview. The FTA portal combines permissions and services from ePortal in one central location. The FTA is gradually migrating the online services to the new FTA portal.
Top-up tax: temporal application and exercise of elections of the administrative guidance of 5 January 2026 on the Side-by-Side Package
The FTA provides information on the effective date of the new safe harbor rules in the context of the minimum taxation of large multinational corporate groups. With regard to the applicable accounting standard for the Simplified ETR Safe Harbor, reference is made to Article 9 paragraphs 2 and 3 of the Minimum Taxation Ordinance (OMinT).
Contact
Please use the contact form for enquiries and to request a callback. If you would like us to call you back, please select the option ‘Would you like us to call you back?’ on the contact form and briefly describe your matter. Many thanks in advance.
Submit a ruling
To submit a transfer pricing ruling, please use the following email address: transferpricing(at)estv.admin.ch.
Federal Tax Administration FTA
Team Transfer Pricing
Eigerstrasse 65
3003 Berne