The transfer pricing guide includes a jurisdiction-by-jurisdiction overview of the transfer pricing rules in place and everything you should be aware of, from Country by country reporting to exemptions and related developments.
Transfer prices must be tax-compliant, economically sound and properly documented.
We can advise you on the structure, analysis and documentation of your intra-group transfer pricing arrangements – from functional and risk analyses to advance pricing agreements and representation during tax audits. Our approach combines regulatory expertise with a pragmatic understanding of your business operations.

Our services
- Reviewing business activities / models relating to BEPS (OECD project concerning the reduction and transfer of profits) and assessing any risks
- Assessing possible differences between the contractual and operational company organisation, including:
- value chain (risks, functions and assets)
- processes
- group transactions
- transfer pricing methods
- Creating business models and group structures with solid substance
- Implementing intellectual property rights and financing structures
- Optimising the value chain
- Preparing OECD-compliant local and master documentation
- Defending transfer pricing documentation vis-à-vis the Swiss tax authorities in assessment procedures and during audits
- Negotiating tax and transfer pricing agreements (Advanced Pricing Arrangements – APAs)
- Coordinating transnational reporting projects (Country-by-Country-Reporting – CbCR)
- Determining, quantifying, administering and monitoring transfer prices and tax risks taking current BEPS developments into account