Transfer pricing is one of the most critical and closely scrutinised tax topics for companies operating across borders. The Organisation for Economic Co operation and Development (OECD) define transfer pricing as the prices at which tangible goods, intangible assets or services are transferred between associated enterprises.

In today’s environment of increased transparency, BEPS requirements and aggressive tax audits, transfer pricing directly affects a group’s effective tax rate, compliance risk and reputational exposure. Beyond compliance, a well designed transfer pricing policy can also support business strategy, value creation and sustainable global growth.

RSM Switzerland supports companies in designing robust, defensible and business aligned transfer pricing policies, covering planning, implementation, documentation and audit defence.

Transfer pricing challenges in a global environment

Companies face increasing challenges when managing intercompany transactions, including:

• Diverging local regulations and documentation requirements
• Increased scrutiny by tax authorities
• Automatic exchange of information and BEPS obligations
• Complex value chains involving IP, services, financing and assets

Transfer pricing risks arise across all group functions — R&D, manufacturing, distribution, services, financing and IP ownership — making a fragmented or outdated approach particularly costly.

Our transfer pricing advisory approach

From compliance to strategic alignment

At RSM Switzerland, we view transfer pricing not only as a compliance requirement, but also as a tool to align tax, operational and strategic objectives.

Our specialists work closely with management to:

• Understand the group’s business model and value drivers
• Analyse intercompany transactions and value chains
• Identify transfer pricing risks and optimisation opportunities
• Design policies that are both compliant and pragmatic

A structured four step methodology

Our transfer pricing engagements typically follow a structured process:

1. Understanding the business and its related party transactions
2. Functional and economic analysis of group entities
3. Selection and testing of the most appropriate transfer pricing methods
4. Preparation of robust documentation and defence support

This approach ensures consistency, audit defensibility and operational relevance.

Transfer pricing services

Policy design & implementation

We assist with:

• Definition and implementation of transfer pricing policies
• Review and adjustment of existing policies
• Analysis of intragroup contracts and pricing mechanisms
• Value chain and functional analysis

Documentation & BEPS compliance

Our teams prepare and support:

• Transfer pricing documentation (Master File, Local File)
• Functional analyses and economic benchmarking studies
• Documentation for services, financing, IP and tangible goods
• Support for automatic exchange of information requirements

Audit defence, disputes & risk mitigation

We support companies in:

• Transfer pricing audits and tax authority challenges
• Advance Pricing Agreements (APA) and rulings
• Mutual Agreement Procedures (MAP)
• Risk mitigation through sanity checks and stress testing

Our objective is to minimise double taxation risks and ensure defensible positions.

Special situations & transactions

Transfer pricing often plays a decisive role in:

• Group restructurings and business transformations
• M&A transactions and due diligence
• Transfers of intangible assets and IP
• Financing and cash pool arrangements

RSM Switzerland supports transfer pricing considerations throughout these high impact situations.

Why choose RSM Switzerland for transfer pricing

Swiss expertise, global reach

We combine deep knowledge of the Swiss tax environment with access to the RSM international network, ensuring:

• Consistent methodologies across jurisdictions
• Local insight where it matters
• Coordinated cross border execution

Pragmatic, senior led advisory

Our engagements are led by experienced specialists who focus on:

• Practical, business oriented solutions
• Clear and defensible deliverables
• Direct involvement of senior advisors

We tailor each assignment to the company’s size, complexity and objectives — no “one size fits all” approach.

Who we support

We advise:

• Multinational groups
• Swiss based mid market companies with cross border activities
• Fast growing groups entering new markets
• Companies undergoing restructuring, M&A or strategic change