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An overview by Taxpartner AG, Taxand Switzerland
2025 was a challenging year for MNEs, shaped by geopolitical tensions, changing U.S. customs policies, the Ukraine war, rapid technological advances, and new market competition. Tax authorities have increased scrutiny of intra-group transactions, using AI, Country-by-Country Reporting, and other tools to assess transfer pricing.
Monika Bieri and Manuel Ulrich from our Swiss member firm Taxpartner AG have highlighted the importance for MNEs to proactively manage and document transfer pricing models. Year-end adjustments are increasingly crucial for optimising margins and mitigating tax or customs risks, but they must be applied carefully. Looking to 2026, automation, robust documentation, and proactive operational transfer pricing – including customs management – will be essential for navigating complex regulations, capturing opportunities, and minimising audit risks.
You can read the full overview here.
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Compliance | Cross border | International Tax | OECD | Reporting | Switzerland | Tax | TP & Business Restructuring | Transfer Pricing