Workshop by Ivo Manatschal, Simona Studer and Thomas Hug on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Transfer pricing documentation - International and Switzerland"
Note: This language version is an automatically generated translation. The text may therefore contain linguistic and terminological errors.
view in original language (German)The ABC Group, headquartered in Switzerland, operates in numerous countries within and outside Europe. Due to its corporate structure, it engages in many transactions between group companies and must therefore prepare transfer pricing documentation in various countries. The tax law of Country X requires the ABC Group to prepare transfer pricing documentation for its subsidiary there in accordance with the “requirements of the OECD Transfer Pricing Guidelines.”
The ABC Group charges for a brand license within its group and must prepare a benchmark study as part of its transfer pricing documentation. It finds 200 comparable transactions between independent third parties in commercial databases.
A routine company within the ABC Group is remunerated with an EBIT margin of 1.5% based on the transaction-based net margin method. The arm’s length margin according to transfer pricing documentation falls within a narrow range of 2.5% to 8%, with a median of 4%.
In year N, the ABC Group carries out an intra-group transaction and prepares a benchmark study for this purpose.
