CH Transfer Pricing
Swiss transfer pricing for 2026. Switzerland has no transfer pricing statute: the arm's length principle works through profit tax (DBG art. 58 para. 1 let. b and c, StHG art. 24) and the 35% withholding tax on hidden profit distributions (geldwerte Leistungen, VStG art. 4 para. 1 let. b). Covers related parties, hidden profit distributions and hidden capital contributions, the ESTV safe-harbour interest rates for 2026 (CHF and foreign currency), service companies (Kreisschreiben 4), the burden of proof, rulings, APAs, MAP (StADG), country-by-country reporting (CHF 900 million), penalties, and the 35% withholding with the gross-up when it is not passed on.
Not yet approved
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