The Swiss Federal Tax Administration published a new Transfer Pricing Guide on 23 January 2024. The guide considers Swiss law as of 1 January 2024 and provides:
- An overview of the arm's length principle and the consequences of non-compliance of the arm's length principle under Swiss law, including that where excessive remuneration is paid to related parties (or insufficient remuneration is received), this is treated as a hidden distribution of profit that is reintegrated into the taxable pr…