At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: Eidgenössische Steuerverwaltung (ESTV) / Federal Tax Administration (FTA); the cantonal tax administrations assess corporate income tax. Summaries are simplified; check the linked official source before relying on them.
The law
#Switzerland has no dedicated transfer pricing statute. The arm's length rule works through the hidden profit distribution rules: Art. 58(1)(b) of the federal direct tax act (DBG) and Art. 24(1)(a) of the tax harmonisation act (StHG) for profit tax, and Art. 4(1)(b) of the withholding tax act (VStG) with Art. 20 of its ordinance (VStV) for 35% withholding tax. An excessive payment to a shareholder or related party, or too little received from one, is added back to taxable profit. The cantons assess profit tax and make the primary adjustments, and the ESTV handles withholding tax as the secondary adjustment. The OECD Guidelines (2022) are not binding, but authorities and courts use them more and more to read the Swiss rule, and ESTV circular no. 4 of 19 March 2004 tells the cantons to take them into account.
Documentation
#There is no statutory master file or local file duty. The only mandatory TP document is the country-by-country report. Every taxpayer must still give information and hand over books and records on request (Art. 126 DBG, Art. 42 StHG, Art. 39 VStG), and must keep them for ten years (Art. 126(3) DBG). In practice the taxpayer has to show that intra-group prices are at arm's length, and ruling requests need a TP study. If the records are missing or unreliable, the authority can assess at its discretion (Art. 130(2) DBG). The OECD three-tier approach is a guide and not a Swiss duty.
Methods
#The ESTV and the Swiss Tax Conference (SSK) describe the OECD methods: CUP, resale price, cost plus, TNMM and profit split, plus other methods where needed. The OECD nine-step comparability analysis is called good practice but is not mandatory. Safe harbours exist for financing. Each January the ESTV publishes circulars with accepted interest rates for intra-group loans in CHF and in foreign currencies. For 2026 a loan funded from equity must bear at least 0.75% in CHF, and higher rates can be defended with a third-party comparison. Hidden equity (thin capitalisation) follows ESTV circular no. 6a of 10 October 2024.
Penalties
#There is no TP-specific penalty, so the general rules apply. A taxpayer who does not file a return or give information despite a reminder can be fined up to CHF 1,000, or up to CHF 10,000 in serious or repeat cases (Art. 174 DBG). The authority can assess at its discretion (Art. 130(2) DBG). An unjustified deduction that leaves an assessment incomplete can lead to a tax evasion fine, normally one times the tax evaded and between one third and three times (Art. 175 DBG), plus back tax. A CbC report filed late costs CHF 200 per day up to CHF 50,000 (Art. 12 ALBAG), and intentionally false or incomplete CbC data can be fined up to CHF 100,000 (Art. 25 ALBAG).
Pillar Two
#The Swiss top-up tax is set by the Minimum Tax Ordinance (MindStV, SR 642.161). The domestic top-up tax (QDMTT) applies to fiscal years beginning on or after 1 January 2024 and the IIR to fiscal years beginning on or after 1 January 2025. The UTPR (Art. 10(3)) applies from a later date that has not been fixed. Each liable unit registers, then files the top-up tax return with its canton and the GIR with the ESTV, within 15 months after year end (18 months for a group's first year), and the tax is due the same day (Art. 20, 27, 28d). The CHF 200 per day late charge and fines for negligent breaches fall away for fiscal years that begin by 31 December 2026 and end by 30 June 2028 (Art. 40(3)).
Other rules
#Unilateral rulings are available: profit tax rulings come from the canton and withholding tax rulings from the ESTV (ruling.dvs@estv.admin.ch), and both want a TP study. Bilateral APAs and mutual agreement procedures are handled by the State Secretariat for International Finance (SIF). Deemed distributions carry 35% withholding tax and are declared on form 102 within 30 days of falling due, and the ESTV can make this secondary adjustment whether or not the canton made a primary one. Federal deadlines that end on a Saturday, Sunday or public holiday move to the next working day (Federal Act on Time Limits on Saturdays Art. 1, Art. 78 OR, Art. 20(3) VwVG).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC registration (Anmeldung) with the ESTV, one-time Due 90 days after the end of the reporting period (Art. 10(4) ALBAG): 31 March for a 31 December year end (30 March in a leap year), 29 June for 31 March and 28 September for 30 June. It is a registration, not a yearly filing: once registered, the entity only deregisters when it stops being the reporting entity (Art. 10(4)). The date shown applies to the first reporting year. The entity gives its status as parent or substitute parent, name and seat, UID and start date. Other Swiss group entities have no notification duty, because the Federal Council has not used its power in Art. 10(3). | 90 days after year end (e.g. Mar 31, 2026) | The reporting entity (Swiss ultimate parent or substitute parent) of a group whose consolidated revenue in the prior year was more than CHF 900m. | ALBAG Art. 10 (Fedlex) |
| 2 | Corporate income tax return (Steuererklärung juristische Personen), cantonal The federal law sets no date. Art. 124 DBG only says to file on time, and each canton sets its own deadline. The tax period is the business year, and the cantons send the return form early in the next calendar year with a fixed date in that year, so the date does not move with the year end month (Basel-Stadt: 30 June of the calendar year after the tax period). 30 June is the most common date, used by 11 of 26 cantons in an official Schwyz government table of October 2023 (AR, BL, BS, GL, NW, OW, SG, SO, TI, TG, VS). Several cantons are earlier: Neuchâtel 25 March, Geneva 30 April, Appenzell Innerrhoden and Jura 31 May. Others are later: Bern, Uri and Schwyz 31 July, Fribourg and Lucerne 31 August, Zurich, Zug, Graubünden and Schaffhausen 30 September, Aargau 31 October, and Vaud uses 255 days after year end. Extensions are usually granted on request, mostly to 31 December, but Zurich only to 30 November, Bern 15 November, Thurgau, Valais and Jura 31 October and Geneva 30 September, while Zug allows up to 30 June of the following year. Check the date printed on your canton's return form. Penalty for no return after a reminder: fine up to CHF 1,000, or CHF 10,000 in serious cases (Art. 174 DBG). | Extended: extension on request, commonly granted to 31 December of the year after the tax period (some cantons allow less, e.g. Zurich 30 November, Bern 15 November) (e.g. Dec 31, 2026); original due date Jun 30, 2026 | Every company with its seat in Switzerland. The canton of the seat sets the deadline. The federal direct tax and the cantonal and communal taxes are filed on one return. | Schwyz Regierungsrat, RRB 723/2023 (cantonal comparison of filing deadlines) |
| 3 | Country-by-country report to the ESTV Filed with the ESTV no later than 12 months after the end of the reporting period (Art. 11(1) ALBAG). The ESTV passes it to partner countries and to the cantons. Weekends and holidays: Saturdays are treated like public holidays for federal statutory periods (Federal Act on Time Limits on Saturdays, Art. 1), and the next working day rule applies to Sundays and holidays (Art. 78 OR, Art. 20(3) VwVG). A late report costs CHF 200 per day, max CHF 50,000 (Art. 12 ALBAG). | 12 months after year end (e.g. Dec 31, 2026) | Swiss-resident ultimate parent or substitute parent of a group with consolidated revenue of more than CHF 900m in the year before the reporting year. The ESTV can also order another Swiss group entity to file if the parent's country has no exchange agreement or the exchange has failed (Art. 8 ALBAG). | ALBAG Art. 11 (Fedlex) |
| 4 | Top-up tax and GIR registration (information systems) Each business unit liable for the top-up tax must register on its own initiative in the cantonal top-up tax information system, and the GIR filer must register in the ESTV GIR system, within the same deadlines as the return (Art. 19(1), Art. 28m MindStV). Registration stays valid until the filing duty changes, and a unit must deregister when its duty ends. | With Top-up tax return (Ergänzungssteuererklärung) (e.g. Mar 31, 2027) | Swiss business units of groups with consolidated revenue of at least EUR 750m (MindStV Art. 8). Groups that meet the test in at least two of the four preceding fiscal years follow the GloBE rules. | MindStV Art. 19 and 28m (Fedlex) |
| 5 | Top-up tax return (Ergänzungssteuererklärung) Filed with the competent cantonal authority within 15 months after the end of the GloBE fiscal year, or within 18 months for the first return after the group enters scope (Art. 20(1) MindStV). Swiss top-up tax, IIR and UTPR are assessed in separate decisions (Art. 22). Swiss QDMTT applies to fiscal years beginning on or after 1 January 2024, the IIR from 1 January 2025. The UTPR date is not set yet. The first return, for calendar 2024, was due 30 June 2026. For a 31 December 2025 year end the site assumes 15 months, which gives 31 March 2027. A group that newly enters scope in 2025 or later gets 18 months for its first year, which the site cannot detect. Weekends and holidays move the date to the next working day (Art. 14 MindStV applies Art. 133(1) DBG by analogy; Art. 78 OR; Art. 20(3) VwVG). | 15 months after year end (e.g. Mar 31, 2027) | Swiss business units of groups with consolidated revenue of at least EUR 750m (MindStV Art. 8). Groups that meet the test in at least two of the four preceding fiscal years follow the GloBE rules. | MindStV Art. 20 (Fedlex) |
| 6 | GloBE Information Return (GIR) to the ESTV Filed with the ESTV in XML (OECD schema) through the ESTV e-portal within the same deadlines as the top-up tax return (Art. 28c and 28d MindStV): 15 months, or 18 months for the first year, so 30 June 2026 for calendar 2024. A Swiss unit need not file if another Swiss unit files it, or if a group unit files in a partner country with a working exchange agreement. It then only states who files and where. Late filing costs CHF 200 per day, max CHF 50,000 (Art. 28e), but this charge falls away for fiscal years beginning by 31 December 2026 and ending by 30 June 2028 (Art. 40(3)). The GIR rules apply to fiscal years beginning from 1 January 2024. The automatic GIR exchange with partner states starts only when the GloBE Multilateral Agreement is in force. | 15 months after year end (e.g. Mar 31, 2027) | Swiss business units of groups with consolidated revenue of at least EUR 750m (MindStV Art. 8). Groups that meet the test in at least two of the four preceding fiscal years follow the GloBE rules. | MindStV Art. 28c to 28e (Fedlex) |
| 7 | Top-up tax payment The top-up tax falls due at the same time as the return deadline (Art. 27(2) MindStV). There is no separate payment date. The cantons bill the tax and share it with the Confederation. | With Top-up tax return (Ergänzungssteuererklärung) (e.g. Mar 31, 2027) | Swiss business units of groups with consolidated revenue of at least EUR 750m (MindStV Art. 8). Groups that meet the test in at least two of the four preceding fiscal years follow the GloBE rules. | MindStV Art. 27 (Fedlex) |
| 8 | Transfer pricing documentation (no statutory file, handed over on request) The authority sets a reasonable period when it asks for information (Art. 124(3), 126(2) DBG). No fixed number of days exists in the statute. Keep books and records for ten years (Art. 126(3) DBG). Records that are missing or unreliable can lead to a discretionary assessment (Art. 130(2) DBG). Ruling requests need supporting documents such as a TP study. | See note | No Swiss threshold. There is no legal duty to prepare a local file. Every taxpayer must be able to show arm's length pricing when the tax authority asks. | ESTV / SSK Steuerdokumentation: Verrechnungspreise (January 2024), section 6 |
| 9 | Withholding tax declaration of deemed distributions (form 102) The benefit must be declared on form 102 on the company's own initiative within 30 days after it falls due. The 35% withholding tax is payable in the same period. The date runs from the due date of each benefit, not from year end, so no calendar date is shown. | See note | Swiss companies that make a benefit in money's worth to shareholders or related parties, for example an interest-free or underpriced loan or an excessive payment. | ESTV circular 2-218-DV-2026-d (interest rates 2026, CHF) |
Official texts
#- Swiss federal law texts: DBG, StHG, VStG, VStV, ALBAG, ALBAV, MindStV, VwVG, OR (Fedlex, official German version) (No copyright in laws, ordinances and other official enactments (Art. 5(1)(a) URG). Quote with the source. The official Fedlex terms page could not be read, so any extra attribution wording there is unconfirmed.)
- ESTV / SSK Steuerdokumentation: Verrechnungspreise (January 2024) and ESTV interest rate circulars 2026 (Public ESTV publications. The Steuerdokumentation allows non-commercial quotation with the source named. Art. 5(1)(c) URG excludes authority reports from copyright, but this was not tested for these documents.)