Transfer Pricing: Rules and Practice in Selected Countries (Q-S) (Portfolio 6970)

Tax Management Portfolio, Transfer Pricing: Rules and Practice in Selected Countries (Q–S), No. 6970, presents the rules and practice related to transfer pricing in Singapore, Spain, Sweden, and Switzerland.

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Chapter 145, “Transfer Pricing Rules and Practice in Singapore,” provides an overview of the rules and practice of transfer pricing in Singapore with regard to determining arm's-length pricing. The term “arm's length” is not defined in the Singapore Income Tax Act (Chapter 134 of Singapore) (ITA), but there are specific provisions in the ITA that require transactions between related parties to be conducted on similar bases as unrelated parties would conduct those transactions. Transfer pricing guidelines have been issued by the Inland Revenue Authority of Singapore (IRAS). The material in the chapter is current as of September 2013.

Chapter 150, “Transfer Pricing Rules and Practice in Spain,” begins with an overview of the main characteristics of Spain's economy and of the Spanish tax system, and then provides a detailed discussion of the Spanish transfer pricing rules and regulations. The chapter includes an analysis of the specific rules and regulations that are provided under Spanish law for services, cost-sharing arrangements, and loans and thin capitalization. The chapter also discusses transfer pricing audit procedures in Spain as well as the consequences of a transfer pricing adjustment, both from a domestic perspective and from an international dispute resolution point of view. Finally, the chapter discusses the Advance Pricing Agreement alternative that is available to Spanish taxpayers as well as the relevant transfer pricing case law.

Chapter 155, “Transfer Pricing Rules and Practice in Sweden,” provides an overview of the Swedish tax system, particularly the provisions applicable to operating a controlled group of companies, including the rules for tax consolidation, restrictions on interest deductibility, payment of group dividends, and taxation of controlled foreign corporations. The chapter then analyzes in depth the relevant provisions in Swedish tax law governing transfer pricing adjustments, including the definition of an arm's length price in the controlled group context, the examination process, taxpayer documentation requirements, settlement of transfer pricing disputes through arbitration or the competent authority process, and the advance pricing agreement regime. The chapter also examines significant transfer pricing cases, potential defenses, and tax treaty provisions relevant to transfer pricing issues involving Sweden and the United States.

Chapter 160, “Transfer Pricing Rules and Practice in Switzerland,” analyzes the Swiss federal and cantonal rules and procedures for making transfer pricing adjustments. In many countries there are specific rules for setting or evaluating prices for related-party services, licenses, or sales of goods or intangibles. Switzerland, however, has even today only rudimentary rules dealing with transfer pricing and Swiss tax administrators often simply lack the capacity to audit complex transfer pricing arrangements. The reason for this is that historically multinational enterprises generally used Switzerland's beneficial tax environment to shelter profits, and thus transfer pricing was seldom used to reduce profits in Switzerland. Nowadays, in today's worldwide transfer pricing environment, Swiss multinational enterprises and multinationals with Swiss-affiliated companies are more often confronted with foreign transfer pricing adjustments which may affect the taxable base of a Swiss company and thus present the possibility of double taxation. In such a situation, a knowledge of Swiss transfer pricing rules and practice is necessary in order to persuade the Swiss tax authorities that a corresponding adjustment is appropriate, either unilaterally or as part of a mutual agreement procedure.


Tax Management Portfolio, Transfer Pricing: Rules and Practice in Selected Countries (Q–S), is authored by the following experts.
Edmund Leow, Esq.

Edmund Leow has been appointed a judicial commissioner in the Supreme Court of the Republic of Singapore and is currently on leave from his position as managing principal at Baker & McKenzie.Wong & Leow. In his position at Baker & McKenzie he has advised on international tax and trade law matters, including cross-border tax planning, transfer pricing, and tax disputes. Leow received his BA in law from the University of Cambridge.

Allen Tan, Esq.

Allen Tan, a partner with Baker & McKenzie.Wong & Leow, has extensive experience working on both international and local tax issues, and is listed as a leading tax lawyer in several world's leading legal directories including Chambers Asia and Legal 500. His practice includes advising clients on tax issues arising from mergers and acquisitions, private equity and hedge fund structuring, indirect taxes, transfer taxes, tax controversies, foreign direct investment and cross-borders tax planning issues. He also advises on customs and free trade agreements. Allen has previously handled a mixture of commercial and employment work, as well as advised on cross-border mergers and acquisitions. His diverse experience has proven invaluable in factoring both commercial and practical elements into his tax solutions for his clients. In addition, Allen advises on wealth management matters for both high net-worth families and institutional clients.

Peter Tan, Esq.

Peter Tan, Senior Tax Consultant at Baker & McKenzie.Wong & Leow, is a Barrister from Middle Temple, Inns of Court, London, UK. Mr. Tan began his tax career in the UK and continued his specialization in Singapore where he was with KPMG and then PwC, of which he was a tax partner. Peter has advised clients from a variety of industries and on a wide spectrum of areas such as business and group restructuring, mergers and acquisitions, tax incentives, intellectual property migration, licensing and franchising, royalty flows and financial products. He has also been engaged for tax dispute resolution with tax agencies. He has been voted as a top individual tax advisor in Singapore for several years.

Christopher J. Newman, Esq.

Chris Newman is an Executive Director in the Tokyo office of Ernst & Young Shinnihon Tax. He has more than 15 years of transfer pricing experience while working in the United States, Japan (five years), and Singapore (five years), including consulting on international transfer pricing issues in the Asia-Pacific. Mr. Newman has advised clients spanning a wide range of industries on transfer pricing planning, documentation, and controversy in the Asia-Pacific region. He has significant experience on transfer pricing for intangibles, including buy-in and buy-out payments for acquired and developed technologies, marketing intangibles, and cost-share payments. Mr. Newman has been engaged on projects for ASC 740-10 (FIN 48) reporting, and on calculating and documenting complex service fee charges. Additionally, he is a frequent speaker at transfer pricing symposia in the Asia-Pacific region. The views attributed to Mr. Newman in this chapter are his views and do not necessarily reflect the views of other members of the global Ernst & Young organization.

Wei Kee Ho, Esq.

Wei Kee Ho is currently a director in a global bank. He was previously an associate in the Singapore office of Baker & McKenzie, where he advised both multinational and local clients on income tax and indirect tax matters. He also advised private banks, trust companies, and high-net-worth individuals in trust structuring, personal tax, and succession matters. Prior to working at Baker & McKenzie, Mr. Ho worked in the tax practice of a Big Four auditing firm and in the tax departments of various U.S.-listed multinational companies.

Michael W. Walter, Esq.

Michael Walter is a Transfer Pricing partner in PricewaterhouseCoopers' Global Transfer Pricing Group in Madrid. He has worked on a wide range of transfer pricing documentation, company restructuring, and intellectual property migration projects. He has also worked on a number of Advance Pricing Agreements (APAs), and has designed various sensitivity models related to the implementation of alternative business structures. He has also testified as an expert witness in the Spanish Courts in transfer pricing disputes. Michael obtained his Bachelor of Science degree from Bentley College, Boston (1996), his MBA from the University of California, Berkeley (2002), and completed the Chartered Financial Analyst (CFA) program (2005). He participates frequently as a speaker in domestic and international transfer pricing seminars and conferences, and is also a teacher at the Instituto de Empresa in Madrid.

Ramón Mullerat, Esq.

Ramón Mullerat, an international tax partner with PricewaterhouseCoopers Madrid, has over 12 years of experience in international inbound and outbound tax planning. Ramón is the partner in charge of PwC Spain's International Tax Structuring Group and also heads PwC Europe's Latin American Business Center. Ramón's academic qualifications include the ITP Degree from Harvard Law School (1992), an LLM Degree in International Law from Notre Dame School of Law (1989), a Certificate in European Law from the College of Europe in Bruge (1988), and an LLB Degree from the University of London, Faculty of Law (1988). Ramón is a co-author of BNA Tax Management's Business Operations in Venezuela (1st and 2nd editions) and Business Operations in Chile. He is also a frequent contributor of articles to international tax magazines and is the Spanish correspondent for Tax Analysts' Tax Notes International.

Dr. Lars Samuelson

Dr. Lars Samuelson is a Director in the Stockholm office of Svalner Skatt & Transaktion. After obtaining an L.L.D. in fiscal law from Uppsala University in 1994, Dr. Samuelson worked with several Swedish law firms and was a tax adviser at KPMG Sweden from 2003–2011 where his practice included mergers and acquisitions, reorganizations, and transfer pricing. Dr. Samuelson has extensive experience in international corporate taxation involving both private and listed companies.

Richard J. Wuermli

Richard J. Wuermli, Certified Tax Expert with Federal Diploma, joined Deloitte & Touche in 1987 in Zurich and in 1989 was named Partner-in-Charge of the tax and legal department. In 1998 he founded TAX EXPERT International AG in Zurich and Zug and was named Managing Partner. He is a recognized author and speaker and has addressed various national and international tax conferences. He is the author of numerous articles on Swiss and international taxation, and has contributed to the IBFD's loose-leaf publication The International Guide to Mergers and Acquisitions. He is also the author of Mergers and Acquisitions in Switzerland — National and Transnational, published by IBFD. Mr. Wuermli is a member of the traditional guild Kämbel in Zurich, which was established in 1536. He is also a member of the International Fiscal Association, the International Bar Association, the American Bar Association, and the Swiss Accounting and Fiduciary Association.

Katharina B. Padrutt

Katharina B. Padrutt, Certified Tax Expert with Federal Diploma, is a Partner with TAX EXPERT International AG, Zurich, focusing on complex national and international tax structures. She joined TAX EXPERT International AG in 2001, after 10 years as a Tax Manager with KPMG in Zurich. She is an acknowledged speaker in Switzerland and abroad on tax-related topics. She is a member of the International Bar Association and the International Fiscal Association. She is also an author of various national and international specialist publications.

Table of Contents

Portfolio 6970-1st: Transfer Pricing: Rules and Practice in Selected Countries (Q-S)

Portfolio Description


Technical Advisors


Significant Developments

Significant Developments




Administrative Developments

Taxing Authority Creates Office to Scrutinize Aggressive International Tax Planning


Supreme Court Ruling on Permanent Establishment under the Spanish-Swiss Treaty



Board for Advance Rulings Finds PE in Computer Server Activities of Nonresident


Detailed Analysis

CHAPTER 145: TRANSFER PRICING RULES AND PRACTICE IN SINGAPORE  by Edmund Leow, Esq. (Baker &  McKenzie.Wong &  Leow, Singapore) Christopher J. Newman, Esq. (Executive Director, Transfer Pricing, Ernst &  Young Shinnihon Tax, Tokyo, Japan) and Wei Kee Ho, Esq. (Singapore)

145:I. Introduction

145:II. The Transfer Pricing Landscape in Singapore

Introductory Material

A. Statutory Framework

1. Section 33 of the ITA

2. Section 34D of the ITA

3. Section 53 of the ITA

B. IRAS Circulars

1. Transfer Pricing Guidelines (February 23, 2006)

2. Transfer Pricing Consultation (July 30, 2008)

3. Supplementary Administrative Guidance on Advance Pricing Arrangements (October 20, 2008)

4. Transfer Pricing Guidelines for Related Party Loans and Related Party Services (February 23, 2009)

C. OECD Publications

145:III. Application of the Arm's-Length Principle

A. General

B. Comparability Analysis

1. Functional Analysis

2. Loans and Financing Transactions

3. Services

C. Transfer Pricing Methods

1. Comparable Uncontrolled Price CUP) Method

2. Resale Price (RP) Method

3. Cost Plus (CP) Method

4. Profit Split Method

a. Contribution Analysis

b. Residual Analysis

5. Transactional Net Margin (TNM) Method

D. Selection of Method and Tested Party

1. Selection of Method

2. Selection of Tested Party

E. The Arm's-Length Range

F. Adjustments for Differences

145:IV. Corresponding Adjustments

A. Background

B. Applicability of Article 9(2)

1. Article 9 of the OECD Model

2. Article 9(2) in Singapore's Double Taxation Agreements

3. Variations in Singapore's Article 9(2)

C. Mutual Agreement Procedure of Article 25

1. Article 25 of the OECD Model

2. Link Between Article 9(2) and Article 25

3. Limitations of a MAP

4. Filing of a MAP Request

5. Legal Effect of the Mutual Agreement Reached and Pursuit of Other Legal Remedies

D. Advance Pricing Agreements

1. Nature of Advance Pricing Agreements

2. Making an APA Request

145:V. Other Matters Relevant to the Transfer Pricing Circular

A. Reporting Requirements

B. Statute of Limitations

C. Penalties

145:VI. Singapore Avenues of Appeal

145:VII. Conclusions

CHAPTER 150: TRANSFER PRICING RULES AND PRACTICE IN SPAIN  by Michael W. Walter Partner and Ramon Mullerat Partner Landwell PricewaterhouseCoopers Tax &  Legal Services Madrid

150:I. Introduction

Introductory Material

A. Overview of Spain's Economy

B. The 2008-2009 Financial Crisis

C. Unemployment Crisis

D. Economic Ties

150:II. Overview of Spain's Tax System

A. History

B. The Legal Framework

C. Value-Added Tax

D. Transfer Tax

E. Economic Activity Tax

150:III. Overview of Spain's Income Tax System

A. Income Taxation of Resident Corporations

1. Residence

2. Calculation of Taxable Income

a. Worldwide Taxation

b. Taxable Period

c. Determination of Taxable Income

d. Thin Capitalization

e. Net Operating Loss Carryforward

3. Determination of the Corporate Income Tax Liability

a. Tax Consolidation

b. Tax Rates

c. Tax Credits

B. Income Taxation of Non-Resident Corporations

1. Income Taxation of a Spanish Permanent Establishment

2. Withholding Taxes on Income Not Attributable to a Spanish Permanent Establishment

a. In General

b. Dividends

c. Interest

d. Royalties

e. Service Fees

f. Sale of Real Estate

g. Sale of Shares in Resident Companies

150:IV. History of Spain's Transfer Pricing Rules

Introductory Material

A. Practical Considerations with Respect to the 2006–2009 Transition Period

B. Annual General Tax Control Plan

150:V. The Spanish Transfer Pricing Rules

A. Overview

1. Arm's-Length Standard in the Spanish Corporate Income Tax Law

2. Relationship Between Customs and VAT

a. Customs Overview

b. VAT Overview

B. Definition of Controlled Parties

C. Transfer Pricing Methods

D. Transfer Pricing Rules for Different Types of Transactions

1. Services

2. Cost-Sharing Arrangements

3. Loans and Thin Capitalization

4. Permanent Establishments

E. Data Sources Commonly Used in Spain

150:VI. The Spanish Transfer Pricing Rules and the OECD Transfer Pricing Guidelines

150:VII. Documentation and Reporting Requirements

A. Documentation Requirements

B. Reporting Requirements

150:VIII. Penalties

150:IX. Tax and Transfer Pricing Audits in Spain

Introductory Material

A. Main Phases of a Tax Inspection

B. Transfer Pricing Inspection Singularities

1. Separate Liquidation Proposal

2. Implication of Related Parties in the Inspection

3. Independent Valuation

4. Correlative Adjustments

150:X. Administrative Appeals and Litigation of Transfer Pricing Adjustments

150:XI. Resolving Conflicts with Other Countries

Introductory Material

A. Mutual Agreement Procedure Included in Spain's Income Tax Treaties

1. Timing of Request

2. Content of Request

3. Reasons for Denying a MAP Request

4. MAP Initiation

5. MAP Development

6. Establishment of a Consulting Commission

7. MAP Termination

8. Execution of Agreement

9. Alternative Scenarios

a. Scenario 1 — MAP Initiated with the Competent Authority of Another Jurisdiction as a Consequence of the STA's Actions

b. Scenario 2 — MAP Initiated with the Competent Authority of Another Jurisdiction as a Consequence of the Actions of That Jurisdiction's Tax Administration

c. Scenario 3 — MAP Initiated with the Spanish Competent Authority as a Consequence of the Actions of Another Jurisdiction's Tax Administration

B. EU Arbitration Convention

1. Timing of Request

2. Content of Request

3. Reasons for Denying a Request

4. Initiation of Procedure

5. Starting Point of the Two-Year Period

6. Development of Initial Positions

7. Establishment of an Advisory Commission

8. Opinion of the Advisory Commission

9. Final Agreement

10. Alternative Scenarios

a. Scenario 1 — Procedure Initiated with the Competent Authority of Another Jurisdiction as a Consequence of the STA's Actions

b. Scenario 2 — Procedure Initiated with the Competent Authority of Another Jurisdiction as a Consequence of the Actions of that Jurisdiction's Tax Administration

c. Scenario 3 — Procedure Initiated with the Spanish Competent Authority as a Consequence of the Actions of Another Jurisdiction's Tax Administration

150:XII. Adjustments to Be Made in the Wake of a Transfer Pricing Adjustment

A. Correlative Adjustment

B. Secondary Adjustment

150:XIII. Advance Pricing Agreements

Introductory Material

A. Unilateral APAs

1. Initial Undertaking

2. Initiation of the Procedure

3. APA Processing

4. Termination

5. Required Documentation for APAs in Force

6. Timing

7. Modifications to an APA

8. APA Extension

B. Bilateral or Multilateral APAs

1. Procedure Initiation

2. APA Processing

3. Termination

C. APAs Initiated by a Foreign Tax Administration

D. APA Statistics in Spain

150:XIV. Transfer Pricing Case Law

Introductory Material

A. Transfers of Tangible Property

1. Supreme Court, January 10, 2007

2. Supreme Court, February 6, 2008

B. Services

1. National High Court, December 19, 2008

C. Financial Transactions

1. Supreme Court, November 6, 2006

2. National High Court, October 23, 2008

3. National High Court, November 24, 2008

CHAPTER 155: TRANSFER PRICING RULES AND PRACTICE IN SWEDEN by Dr. Lars Samuelson Director Svalner Skatt & Transaktion Stockholm

155:I. Introduction

155:II. Background

A. Main Features of Swedish Corporate Taxation and Tax Administration

1. General Remarks

2. Computational Rules

3. Certain Restrictions on Interest Deductions Related to Intra-Group Acquisitions

B. Income Received by Companies Resident in Sweden

1. Operating Companies

2. Small Businesses (Closely Held Companies)

C. Swedish Income Derived by Nonresident Companies

D. Group Consolidation

E. Group Dividends

F. Controlled Foreign Companies

G. Assessment of Income Tax

H. Audit Procedures

I. Administrative and Judicial Appeals

J. Advance Tax Ruling Procedure

155:III. Application of General Principles to Transfer Pricing

A. General Remarks

B. Denied Deduction — Chapter 16 of the Income Tax Act

C. Exit Taxation — Chapter 22 of the Income Tax Act

D. Concealed Dividends — Chapter 24 of the Income Tax Act

155:IV. Application of Chapter 14 of the Income Tax Act

A. General Remarks

B. The Prerequisites

1. Agreement

2. Economic Community of Interest

3. Deviating Terms of Agreement

4. Reduction of Income Taxable in Sweden

5. Other Reasons for Deviating Pricing

C. Tax Implications Where Chapter 14 Applies

D. Burden of Proof and Level of Proof

E. Administrative Interpretation and Practice

1. Influence of OECD Standards

2. Methods of Establishing the Arm's-Length Price for Swedish Tax Purposes

3. Priority of Methods

F. Case Law

1. General Remarks

2. Tangible Property

3. Intangible Property (Royalties)

4. Services

5. Intra-Group Costs

6. Guarantee Commitments

7. Loans and Credits

8. Cross-Border Contributions

G. Transfer Pricing Application of the Tax Avoidance Act

155:V. Defenses To Transfer Pricing Adjustments

A. Business Reasons

B. Set-Off Arguments

155:VI. Swedish Tax Treaty Provisions Relevant to Transfer Pricing

A. General Remarks

B. Swedish Double Tax Treaty with the United States

155:VII. Conflict of General Principles, Chapter 14 and Treaty Law

A. General Remarks

B. Conflict of General Principles and Chapter 14

C. Conflict of Domestic Rules and Treaty Rules

155:VIII. Corresponding and Secondary Adjustments

A. General Remarks

B. Corresponding and Secondary Adjustments

155:IX. Competent Authority Proceedings (Mutual Agreement)

155:X. Arbitration

A. Arbitration Under Swedish Tax Treaties

B. EC Arbitration Convention

155:XI. Transfer Pricing Reporting and Documentation Requirements

A. Swedish Reporting Requirements

B. Swedish Documentation Requirements

C. Coordination with U.S. Documentation Requirements

155:XII. Penalties and Interest on Additional Income Taxes due to Transfer Pricing Income Adjustments

A. Penalties

B. Interest

155:XIII. Dealing with the Swedish Tax Authorities on Transfer Pricing Matters

A. General

B. Formal Advance Rulings

C. Swedish Advance Pricing Agreement Regime

D. Swedish Government Participation in U.S. APA Process

155:XIV. Coordination of Transfer Prices with Swedish Value Added Taxes and Customs

A. Value Added Taxes

B. Customs

CHAPTER 160: TRANSFER PRICING RULES AND PRACTICE IN SWITZERLAND  by Richard J. Wuermli and Katharina B. Padrutt TAX EXPERT International AG, Zurich

160:I. Introduction

A. In General

B. Relevance of Transfer Pricing in Switzerland

160:II. Overview of Corporate Income and Capital Tax System in Switzerland

A. Legal Entities Liable for Income and Capital Taxes

B. Income Taxes

C. Capital Taxes

D. Survey of Corporate Tax Rates

1. Federal Income Tax Rate

2. Cantonal and Municipal Income Tax Rates

3. Capital Tax Rates

4. Stamp Taxes

5. Value Added Tax

E. Companies with Tax Privileges

1. Holding Company Status for Cantonal Income Tax

2. Taxation of Administrative Companies

F. Allocation of Income and Capital to Permanent Establishments

1. Intercantonal Double Taxation

2. International Double Taxation

160:III. Legal Basis for Transfer Pricing Adjustments in Switzerland

A. In General

B. Relevance of Commercial and Company Law for Tax Purposes

C. Hidden Profit Distributions (Constructive Dividends, Deemed Dividend Distributions)

D. Associated Companies/Concept of Control

E. The Arm's-Length Principle

1. Laws


b. Withholding Tax

2. Circular Letters

3. Case Law

4. Methods of Establishing Arm's-Length Prices

160:IV. Specific Transactions between Associated Companies

A. Interest on Loans

B. Thin Capitalization Rules

C. Corporate Valuation

D. Performance of Intragroup Services

E. Principal-Agent Structures (Circular Letter No. 8 of December 18, 2001)

F. Fiduciary Contracts

160:V. OECD Model Tax Convention on Income and on Capital — Relevant Articles

A. Elimination of Double Taxation

B. Article 9 of the OECD Model Tax Convention on Income and on Capital

C. The Mutual Agreement Procedure

D. Attribution of Profits to a Permanent Establishment

160:VI. The Swiss Treaty Practice

A. Article 9(1) — Primary Adjustments

B. Article 9(2) — Corresponding Adjustments

C. Mutual Agreement Procedure

1. Statutes of Limitations

2. Request for a Mutual Agreement Procedure

3. Requirements and Effects

4. Examination of the Request for a Mutual Agreement Procedure

5. Unilateral Remedy Against Taxation in Violation of the Convention

6. Initiation and Execution of the Mutual Agreement Procedure

7. Legal Position of the Taxpayer

8. Legal Effect of an Agreement Reached in the Mutual Agreement Procedure

9. Execution of the Agreement

160:VII. OECD Transfer Pricing Guidelines

A. In General

B. The Swiss Approach

160:VIII. Consequences of Transfer Pricing Adjustments in Switzerland

Introductory Material

A. Primary Adjustment at the Level of the Company Resident Outside Switzerland

B. Corresponding Adjustment at the Level of the Company Resident in Switzerland

1. Swiss Resident Company Has Not Been Finally Assessed

2. Swiss Resident Company Has Been Finally Assessed

C. Secondary Adjustments

D. Swiss VAT Issues

160:IX. Compliance and Litigation

A. Taxpayer — Requirements on Providing Information

B. Information to Be Provided by Third Parties

1. General Rules

2. Penalties

3. Banking Secrecy

C. Position of the Tax Authorities

1. Main Features of the Tax Authorities

2. Position of the Tax Authorities

3. Advance Pricing Agreements

D. Appeals

Working Papers

Working Papers

Table of Worksheets


Worksheet 11 Excerpts from Income Tax Act (Unofficial Translation)

Worksheet 12 Swedish Tax Agency (STA) Guidance

Worksheet 21 Instructions on Fiduciary Contracts (published in October 1967)

Worksheet 22 Circular Letter No. 29 of December 9, 2010, on the Capital Contribution Principle

Worksheet 23 Circular Letter No. 6 of December 22, 2004, on the Notification Procedure on Dividend Distributions by Swiss Companies to Foreign Shareholders

Worksheet 24 Circular Letter No. 6 of June 6, 1997, on the Calculation of Hidden Equity (Thin Capitalization Rules)

Worksheet 25 Circular Letter No. 8 of December 18, 2001, on the International Tax Allocation of Principal Agent Structures for Direct Federal Tax Purposes

Worksheet 26 Instructions of the FTA of February 3 2011, on the Determination of Safe Haven Rules for Interest Payments To and From Shareholder(s) From and To Subsidiaries

Worksheet 27 Instructions of the FTA of June 27, 2011, on the Determination of Safe Haven Rules for Interest Payments in Foreign Currencies To And From Shareholder(S) From And To Subsidiaries

Worksheet 28 Circular Letter No. 4 of March 19, 2004, on the Taxation of Service Companies

Worksheet 29 Circular Letter No. 9 of June 22, 2005, on the Commercially Justifiable Business Expenses of Swiss Companies Mainly Performing Business Activities Outside Switzerland for Direct Federal Tax As Well As for Withholding Tax Purposes





Publications and Treatises




Supreme Administrative Court

Administrative Courts of Appeal

Administrative Guidance

Publications and Treatises




Administrative Guidance

Publications and Treatises