Intercompany Agreement Transfer Pricing Template for Switzerland

1. Force Majeure: Optional clause addressing extraordinary circumstances affecting the transfer pricing arrangement

2. Intellectual Property Rights: Include when the arrangement involves IP transfers or licenses

3. Quality Control: Include for goods transfers or when specific service standards need to be maintained

4. Customs and Import Duties: Include when physical goods are being transferred across borders

5. Advanced Pricing Arrangements: Include if an APA with tax authorities is in place or contemplated

6. Profit Split Provisions: Include when profit split methodology is used

7. Cost Sharing Provisions: Include for arrangements involving shared costs or development activities

8. Step-In Rights: Include when service continuity is critical for group operations

1. Schedule 1 - Service/Product Specifications: Detailed description of services or products covered by the agreement

2. Schedule 2 - Pricing Methodology Details: Detailed calculations, formulas, and examples of price determination

3. Schedule 3 - Cost Allocation Keys: Specific cost allocation methodologies and ratios

4. Schedule 4 - Documentation Requirements: Detailed list of required documentation and maintenance procedures

5. Schedule 5 - Benchmark Analysis: Comparative analysis supporting the chosen transfer pricing method

6. Appendix A - Group Transfer Pricing Policy: Reference to or extract of relevant group transfer pricing policies

7. Appendix B - Compliance Checklist: Checklist for ongoing compliance with agreement terms

8. Appendix C - Related Party Information: Details of group structure and related party relationships