Switzerland: Transfer Pricing

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Article
Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?
The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
Switzerland Tax
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Loyens & Loeff
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