Withholding tax in connection with primary, corresponding and secondary adjustments

Transfer pricing adjustments by the Swiss tax authorities may take the form of a primary adjustment by the competent cantonal tax authority and/or a secondary adjustment by the Federal Tax Administration. When a primary adjustment is conducted by a foreign state, a correlative adjustment may be carried out in Switzerland in order to eliminate double taxation. These different adjustments raise a number of issues relating to withholding tax.

Questions and answers in connection with primary, corresponding and secondary adjustment

Here you will find information on various transfer pricing topics in connection with cross-border transactions. This information is intended to provide clarification on selected issues. It is general in nature and cannot be used as the sole basis for the tax assessment of a specific fact pattern.


Contact

E-Mail

Federal Tax Administration FTA
Team Transfer Pricing
Eigerstrasse 65
3003 Berne

Last modification 20.01.2025

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