Primary, Corresponding and Secondary Transfer Pricing Adjustments

In recent years, Swiss tax authorities, both federal and cantonal, have placed increasing emphasis on transfer pricing issues. They have deployed growing resources to carry out transfer pricing-related tax audits, thereby expanding the number of primary and secondary adjustments affecting Swiss taxpayers. At the same time, the number of mutual agreement procedures involving Switzerland in the field of transfer pricing has also risen. The purpose of this article is to provide a comprehensive, in-depth view of the Swiss legal framework in the field of transfer pricing adjustments and its application by the Swiss authorities, particularly in light of the most recent developments in this area, focusing solely on corporate income tax and withholding tax.