INITIAL SITUATION – GROWN PRICING STRUCTURES WITHOUT A SYSTEM
A mid-sized Swiss company in the electrical engineering sector develops and manufactures its products at its headquarters in Switzerland and distributes them worldwide through its own subsidiaries.
With increasing internationalization, the existing practice of intra-group pricing reached its limits: a lack of comparability, growing complexity, and an increasing sensitivity to tax risks.
What had long worked well was showing growing weaknesses: the intra-group prices had evolved over the years – but without any clear system.
OBJECTIVE – CREATING INTERNATIONALLY COMPLIANT, OECD-CONFORM, TAX-SECURE AND WORKABLE GUARDRAILS
The board of directors mandated the CFO to bring structure to this area. The focus was not only on risk mitigation, but also on the desire to work in the future with clear, robust guardrails.
In discussions with the CFO and his team, it quickly became clear that this would not be a classic transfer pricing project.
A purely formal solution – cleanly documented, but disconnected from day-to-day operations – would have provided little value to the company.
What was needed was an approach that withstands international requirements, is OECD-compliant and audit-proof – while at the same time being accepted in day-to-day business.
OUR APPROACH – DEVELOPING A CONSISTENT SYSTEM WITH ALL STAKEHOLDERS AT THE TABLE
We deliberately set up the project in close collaboration with the finance team – not as an external concept, but as a shared working process.
Through workshops and conversations, we worked step by step to identify which transfer pricing methodology fits the actual value creation. The goal was never the “theoretically best” solution, but one that proves itself in operational practice.
In parallel, the foundations were laid to support such a system. Contractual structures were harmonized, margins were validated through third-party benchmarking, and clear processes and parameters for price-setting were defined.
A key part of the project was anchoring this logic operationally as well. Processes were jointly developed that work in day-to-day business – including a regular review of margins and clear mechanisms for necessary adjustments.
In addition, an OECD-compliant documentation strategy was implemented. Master File and Local Files were established where required or appropriate – not as an end in themselves, but as targeted protection against potential tax risks and in preparation for future audits.
This close and practice-oriented collaboration shaped the project decisively – technically sound, solution-focused, and with a dynamic that is not found in every project.
Or, as the CFO aptly summarized it:
Not an off-the-shelf concept, but jointly developed and efficiently implemented – and
on top of that, a collaboration that was simply enjoyable.
RESULT – MORE CLARITY IN DAILY OPERATIONS AND GREATER SECURITY IN TAX AUDITS
Today, the company has a transfer pricing structure that works in practice and creates confidence.
Pricing within the group is transparent and consistent.
The finance team works with clear guardrails and has the necessary security to make well-founded decisions even in the face of change.
And last but not least, the company is now significantly better prepared for future tax audits – with a structure that is not only documented, but also genuinely lived.
KEY TAKEAWAYS AT A GLANCE:
- Transfer pricing as a practical instrument rather than pure compliance
- Consistent and implementable transfer pricing methodology
- Close collaboration with the finance team
- Benchmarking to validate arm’s-length margins
- OECD-compliant documentation (Master File & Local Files)
- Solid preparation for future tax audits
ABOUT THE AUTHOR
Implementing international transfer pricing projects requires more than technical expertise. As a tax professional with experience in large corporate structures and close collaboration with SMEs in Switzerland and Liechtenstein, Priska Rösli understands not only the tax concepts, but also the internal processes and challenges at the operational level.
That combination is what matters: she brings together deep transfer pricing expertise with a clear understanding of how such concepts can be implemented within existing organizations – pragmatically, efficiently, and in dialogue with the relevant stakeholders. Clients particularly value the fact that she does not merely accompany projects conceptually, but actively co-creates them and supports their execution all the way through. Her goal is
therefore to develop solutions that do not remain in theory, but are viable in practice – transparent, implementable, and sustainably effective.
