International law firm Baker McKenzie’s TP practice offers advice with TP compliance and has a breadth of experience advising in TP contentious matters. However, the team assists with MAP applications, TP planning and TP dispute resolution. Balthasar Denger specialises in transfer pricing and works closely with the tax partners.
Deloitte is highly recommended for its transfer pricing practice, which covers all TP aspects including TP disputes. The experienced TP practice is led by tax partner Salim Damji. The Big Four firm has one of the largest international networks and resources to advise various MNEs and group holding companies in complex TP cases.
The TP team assisted an US group company with transfer pricing work in relation to exit tax. The US group acquired a Swiss group company, and merged its IP and customer contracts. The team’s task involved performing a transfer pricing study and benchmarking study to determine the transfer price of the IP and customer contracts valued at $105 million.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
The tax team at Loyens & Loeff is recommended for its tax legal and transfer pricing services. The firm has offices in Brussels, Zurich and Luxembourg and representatives across America, East Asia and Europe. The firm’s TP practice has five partners, who are spread across Switzerland, Belgium, Luxembourg and the Netherlands. However, Beat Baumgartner, partner, leads the TP practice and works closely with Fabian Sutter, a senior tax adviser in Switzerland. The team specialises in intragroup organisation, financial transactions, asset management services, TP documentation, licensing and intangibles, and TP disputes.
The firm advised a group company in the alcohol industry with relocating its intellectual property, group treasury and cash pooling functions to Switzerland. This entailed thorough Swiss tax analysis for efficient relocation structures, TP advice on cash pooling, tax modelling post relocation and more.
Questro International is an international professional service firm that specialises in transfer pricing and provides full service across its offices in Switzerland, Germany and the Netherlands. The firm’s extensive network spans across 40 jurisdictions, with which it collaborates when handling multi-jurisdiction projects. It was founded in 2013 by Stephen Alleway, former Deloitte Switzerland TP leader, and Peter Andersen (former COO of TP Associates in the Netherlands). The firm has five partners, of which two are in Switzerland.
In recent cases, the firm has assisted a Swiss industrial client with designing and implementing a new TP model, defended two household companies during a TP audit, supported a multinational company with its global documentation strategy and more.
Schellenberg Wittmer is highly recommended for its tax legal services. It is recognised for advising on complex tax cases and providing innovative solutions in tax and transfer pricing issues. The team focuses on assisting in corporate tax, M&A, banking and finance, real estate and litigation cases for private clients, NGOs and corporations. It is comprised of three partners and Michael Nordin and Pietro Sansonetti co-head the practice.
The team represented a Swiss bank in a transfer pricing dispute regarding intragroup transactions for financial products.
The highly recommended tax boutique firm Tax Partner provides full transfer pricing advisory services. The Swiss team is led by Hendrik Blankenstein, partner, who is supported by two counsels specialising in transfer pricing. The TP team offers advice with TP documentation, TP policy, setting up TP management and more. Through the years, the practice has assisted clients ranging from MNEs to family offices, private clients and more. It is a member of the Taxand global network of independent law firms and it is made up of 10 partners and six counsels.
The firm assisted a group company with obtaining advance tax rulings for crucial TP aspects in multiple jurisdictions including Switzerland. This permitted the client to implement a complex intragroup funding structure aligned with its business needs. Other TP work involved supporting the arm’s-length nature of an intercompany interest fee that substantially increased due to increased leverage.