Transfer Pricing 2026

SWITZERLAND Trends and Developments

Trends and Developments Contributed by: René Matteotti, Monika Bieri, Daniel Schönenberger and Manuel Ulrich Tax Partner AG

Tax Partner AG is focused on Swiss and international tax law and is recognised as a leading independent tax boutique. With, currently, 16 partners and counsel and a total of approximately 50 tax experts consist - ing of attorneys, legal experts and economists, the firm advises multinational and national corporate clients as well as individuals in all tax areas. A cen - tral focus lies in tax controversy and dispute reso - lution, including transfer pricing issues. Tax Partner

AG also provides support regarding transfer pricing studies and the preparation of transfer pricing docu - mentation. Other key areas include M&A, restructur - ing, real estate transactions, financial products, VAT and customs. Tax Partner AG is independent and collaborates with various leading tax law firms glob - ally. In 2005 the firm was a co-founder of Taxand, the world’s largest independent organisation of highly qualified tax experts.

Authors

René Matteotti is a tax attorney and professor of law specialising in Swiss, European and international tax law at the University of Zurich. He heads the tax controversy department of Tax Partner AG. His areas of expertise

Daniel Schönenberger is a counsel with Tax Partner AG. Before joining Tax Partner AG in 2024, he worked for more than 20 years for a Big Four firm in the transfer pricing and value chain transformation team. His consulting

include transfer pricing and government advisory work. He represents clients before tax authorities and courts, primarily supporting multinationals with disputes in complex cases. René also routinely provides legal opinions to government agencies and business associations on complex tax law issues. He is a Tax Chapter member of EXPERTsuisse, the Swiss-American Chamber of Commerce and the Joint Tax Committee of the German, Austrian and Swiss Tax Expert Associations; editor-in-chief of the Swiss tax journal ASA; and President of the Swiss Association of Tax Law Professors.

focus is on transfer pricing planning, design, implementation, documentation and defence of business models and transactions of all kinds. He has broad industry knowledge with in-depth project experience in topics related to transfer pricing, such as corporate tax, VAT, customs and valuation. Daniel is a speaker at selected tax seminars and the author of various publications in the field of transfer pricing.

Manuel Ulrich is a senior adviser with Tax Partner AG with more than 15 years of experience in tax advisory, and over ten years in transfer pricing at Big Four companies in Germany and Switzerland. Since December

Monika Bieri is a partner with Tax Partner AG and has around 20 years of experience in national and international tax law. She began her career as a tax consultant with a Big Four firm. After having worked in the

2025, Manuel Ulrich has worked as senior adviser at Tax Partner. He focuses on transfer pricing projects advising multinationals of different sizes and operating in a multitude of industries in transfer pricing planning, documentation and defence of transfer pricing models, value chain restructuring, rulings with tax authorities as well as with tax/ transfer pricing due diligence. In addition, Manuel Ulrich is a speaker at selected educational institutions.

tax department of an international group, Monika joined Tax Partner AG in 2016 as a consultant on international corporate tax law issues and transfer pricing. She is the author of various publications in the field of national and international tax law. Monika holds an LLM in international taxation.

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