Exchange of services between affiliated companies

When:
5
.
February
-
.
2025
|
09.00 - 17.30
Webinar - ISIS) - Institute of Swiss and International Tax Law
Pin Location - ISIS) - Institute of Swiss and International Tax Law
Online - ISIS) - Institute of Swiss and International Tax Law
Pin Location - ISIS) - Institute of Swiss and International Tax Law
Online - ISIS) - Institute of Swiss and International Tax Law
Place:
Renaissance Zurich Tower Hotel, Turbinenstrasse 20, 8005 Zurich
*
+ online!
Price:
1090
|
Members & Reduced:
CHF
990
(incl. VAT)
Info - ISIS) - Institute for Swiss and International Tax Law
Language:
German
Reference:
25/302
-
Integration seminar
Info - ISIS) - Institute for Swiss and International Tax Law
Management:
Thomas Hug

Content

The issue of remuneration for the exchange of services between affiliated companies has also become increasingly important in Switzerland in recent years. This is reflected not least in the fact that the cantonal and federal courts are increasingly having to deal with transfer pricing disputes, whether in inter-cantonal or inter-national situations. On the one hand, the integration seminar places the topic theoretically in the context of Swiss tax law and, on the other hand, teaches how transfer prices for typical transactions are determined in practice. Compact workshops of 50 minutes each are held for this purpose. Particular attention will also be paid to how the topic can be implemented pragmatically in SME structures.

Main topics

- Program -

Transfer pricing in Swiss tax law

-

Unit

Legal classification of transfer pricing in Swiss tax law (DBG, VStG, MWSTG, StG, DBAs), role of the OECD Transfer Pricing Guidelines in national tax law
 Patrick Scherrer Patrick Scherrer
Nils HarbekeNils Harbeke

Comparability and appropriateness analysis

-

Unit

Structure of a comparability analysis in accordance with the OECD Transfer Pricing Guidelines, overview of various transfer pricing methods (functionality, strength/weakness, typical area of application), database analyses, methodological issues (narrowing of bandwidths, mean values, price setting vs. price verification)
Kayla EberliKayla Eberli
Dagmar IhleDagmar Ihle

Financing

-

Workshop

Similarities and differences between Swiss safe harbor practice (safe harbor interest rates, hidden equity) and OECD Transfer Pricing Guidelines, current court rulings (e.g. short/long-term cash pool deposits)
Stefan OesterheltStefan Oesterhelt
Thomas HugThomas Hug

Intellectual property rights

-

Workshop

Definition of intellectual property rights, intra-group attribution of intellectual property rights (legal ownership, financial ownership, functional ownership, DEMPE concept), outsourcing of DEMPE functions, transfer pricing methods for transactions with intellectual property rights (price comparison method, other methods)
Nathaniel ZahndNathaniel Zahnd
Balthasar DengerBalthasar Denger

Production & distribution

-

Workshop

Various organizational forms for production (contract manufacturing, make-to-order production, in-house production) and distribution (commission agents, low-risk distributors, fully-fledged distributors), transfer pricing methods
Flora MarinFlora Marin
Manuel UlrichManuel Ulrich

Reorganizations

-

Workshop

Post-M&A restructurings, relocation of functions and business operations, current court decisions
Patrick SchmidPatrick Schmid

Services

-

Workshop

Concept of services, shareholder costs, benefit test, transfer pricing methods (price comparison methods, cost mark-up method, TNMM, direct vs. indirect offsetting)
Gerhard FothGerhard Foth
Beat GubelmannBeat Gubelmann

Transfer pricing for SMEs

-

Importance of transfer pricing in SME structures, pragmatic solutions, problems of transfer pricing documentation
Stefan PillerStefan Piller
Rita SommarivaRita Sommariva

- Program end -

Useful tips

Discounts

Members of ISIS, employees of courts and administrations as well as persons under 35 years of age or in training receive a discount on the regular seminar price (for details see section 6 of the GTC).

Online / Hybrid

You can participate in this seminar both on-site and virtually.

Included in the price

Documentation; in case of on-site participation also stand-up lunch and refreshments during breaks

Professional training

Participation in the one-day ISIS) seminar is confirmed with 8 lessons of professional development.

Why ISIS Seminars?

  • Top speakers
  • Exclusive venues
  • Personal networking
  • High quality documents
  • Detailed solution instructions
Continuing education in tax law
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Compact seminars

You want to build a solid foundation: Compact seminars

In the compact seminars, you will acquire the basic knowledge of Swiss and international tax law in individual topic-related modules. These basics are supplemented by the latest developments in tax law.

The compact seminars are usually one-day events at a central location, but they can also be attended as an online event via streaming.

For preparation and for reference after the seminar, you will receive documents with case studies and detailed solution instructions. The seminar will focus on discussing the case studies.

Integration seminars

You want to think outside the box: Integration seminars

On the one hand, the integration seminars provide you with the basics from cross-tax knowledge areas, for example basic legal and business management knowledge. On the other hand, you can deal in depth with the tax issues arising in this context on the basis of practical case studies.

The integration seminars are usually one-day events with introductory speeches as well as presentations on the respective cross-tax topics. The tax-specific issues are dealt with by discussing case studies.

In-depth seminars

You want to get to the bottom of tax law: In-depth seminars

The in-depth seminars provide an intensive examination of complex tax issues. The in-depth seminars are mainly or exclusively designed as workshops. After a brief introduction to the topic, practical examples are presented with the aim of stimulating in-depth discussions.

In order to leave enough time for the exchange of ideas
also outside the workshops, the in-depth seminars are partly two-day events, where special emphasis is also placed on the ambience.

The in-depth seminars are aimed at experienced tax professionals and those who want to become one.

Working Skills Seminars

You want to develop your secondary virtues: Working Skills Seminars

Within the framework of the working skills seminars, you can train your non-tax-specific skills that are important for success in tax practice. For example, working techniques, creativity or communication skills.

These seminars are held only sporadically.

Update Seminars

You want to be "à jour": Update seminars

In the update seminars, we take changes in tax legislation as well as in related areas of law and changes in tax practice by tax authorities as an opportunity to take a close look at the effects on tax practice. In doing so, the basics are also presented, as far as this makes sense.

Update seminars also include the 90-minute webinars, which are held exclusively online during lunchtime. They focus primarily on current developments.

Seminars Romandie

The ISIS in French-speaking Switzerland

ISIS is also present in French-speaking Switzerland and offers seminars in French. As a rule, these are in-depth seminars. The topic is always selected in the light of current developments.

Tax Trips

You want to expand your horizons: Tax Trips

The Tax Trips take you abroad and offer the opportunity to combine the useful with the pleasant. You travel to other countries and get to know not only their tax peculiarities, but also their cultural and culinary specialties. The training events are carried out in close cooperation with local institutions as well as tax experts practicing on site.

Tax Trips take place only sporadically.