Transfer Pricing Rules 2025
Forvis Mazars- Transfer Pricing Rules – the collection of local country transfer pricing requirements across jurisdictions.
Navigate complex transfer pricing challenges with our global expertise and ensure regulatory as well as tax compliance at international level
In today's interconnected business landscape, managing transfer pricing across borders has become increasingly complex.
You want to ensure that your business grows healthily and sustainably, competes strongly and remains agile and resilient in an ever-changing world? We offer a range of transfer pricing management solutions that are tailored to your business and the comfort of compliance with local tax regulations.
Companies that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing compliance is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on business units.
Our approach for transfer pricing
Transfer pricing is under increasing scrutiny around the world. Only a global, multi-layer approach can bring simplicity to this fast-evolving issue. Our group in over 100 countries provides vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our transfer pricing experts who have deep industry know-how and the local and international expertise necessary.
Our international transfer pricing experts include specialists and economists for value chain analysis; a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. Data is the foundation for a robust transfer pricing regime. Recognising this, we have created databases and tools that facilitate the needs of reporting for transfer pricing purposes.
Our expert team delivers a comprehensive transfer pricing solution through our proven four-phase methodology, ensuring your business is both compliant and strategically positioned:
| Risk assessment | Detailed diagnostic analysis identifying potential savings and exposure areas |
| Strategy development | Custom-designed transfer pricing policies aligned with your business model |
| Implementation | Seamless execution of transfer pricing policies with clear documentation |
| Ongoing support | Review of the transfer pricing model, adjustments and improvement, assistance with tax audits, mutual agreement procedures, and advance pricing agreements |
Key benefits
- Ensures compliance with global regulations
- Optimises financial and tax strategies
- Supports risk management and audit readiness
- Enhances strategic alignment of transfer pricing policies with business goals
Our transfer pricing services
We provide expert guidance across all aspects of transfer pricing, including:
Strategic planning & documentation
- Master file and local file preparation
- Country-by-country reporting
- Value chain analysis and transformation
- Economic analyses and benchmarking
Risk management & compliance
- Tax audit support
- Mutual agreement procedures
- Advanced Pricing Agreements
- Risk assessment and mitigation
Specialised solutions
- Cash pools and group-wide financing systems
- Function transfer and exit taxation
- Intangible asset valuation
- Industry-specific compliance strategies
- Audit defence and support
Our tools & solutions for transfer pricing
We know that international companies are increasingly looking to prepare large amounts of their transfer pricing documentation centrally and consistently, so they can reach full coverage efficiently. That’s where our seamless approach comes in.
Reptune, an OECD compliant transfer pricing documentation software allows our global teams to easily monitor workflow management and ensure consistency wherever they are working from. Doing this means you get a service that is fast, efficient and accurate.
It follows a top-down approach where data management starts from the global perspective of the multinational before drilling down to a single group company and its individual transactions.
The software’s dashboard provides visual insight into transaction flows, documentation progress and financial performance, while the status page helps prioritise the work based on local deadlines.
Additional available tools:
- Bloomberg and RoyaltyStat database access
- Automated Country-by-Country-Reporting transmission
- Our platform Signals for data exchange
Our added value
We are the ones who look beyond the numbers and provide judgement, insight and challenge.
- Global expertise and local insight: Our approach blends global expertise with strong local knowledge to ensure compliance and strategic advantage for your organisation.
- Value chain optimisation: Our aim is to use our transfer pricing knowledge to express the economic value of your organisation and ensure compliance.
- Proven methodology: Our four-phase process helps your organisation to provide a clear understanding. It follows the rules and fits your unique business needs.
New Swiss transfer pricing recommendations
The new recommendations on transfer pricing in Switzerland issued in January 2024 by the tax authorities, recall Swiss practice in this area and confirm the application of the arm's length principle in Switzerland in the light of the OECD transfer pricing guidelines. Companies are thus encouraged to comply with these guidelines to ensure transparent and fair tax management in transfer pricing matters.
International tax
In operating in the global economy, businesses and their owners require and choose to make investments in international markets that provide the optimum return. Informed and practical tax advice influences these critical investments and maximises financial returns.
Want to know more?
Nathalie Pellanda Gaud Executive Director - Geneva
