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Swiss Court Rejects Multi-Year Margin ‘Smoothing’ in Transfer Pricing

Summary by Taxand
In a recent landmark ruling, the Zug Administrative Court has confirmed that Swiss tax law requires each financial year to be assessed independently, prohibiting retroactive margin ‘smoothing’ across multiple years.
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TaxandTaxand

Swiss Court Rejects Multi-Year Margin ‘Smoothing’ in Transfer Pricing

In a recent landmark ruling, the Zug Administrative Court has confirmed that Swiss tax law requires each financial year to be assessed independently, prohibiting retroactive margin ‘smoothing’ across multiple years.

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Taxand broke the news in on Friday, May 16, 2025.
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