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Transfer pricing is still very much in governments focus. Over the recent years the OECD Transfer Pricing Guidelines have been substantially revised becoming much more detailed and descriptive. The most recent examples are the OECD's guidance on financial transactions and the OECD guidance on the transfer pricing implications of the COVID-19 pandemic. Both Swiss MNEs and many foreign MNEs with operations in Switzerland need to consider these new developments when managing their transfer pricing. Using various illustrative cases, we will inform on recent trends in international transfer pricing from a Swiss and international perspective while sharing practical tips and lessons learned.
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Hendrik Blankenstein is a counsel of Tax Partner AG and leads its transfer pricing team. From 1989 to 1995, Hendrik worked as an international tax consultant at Big 4 firms in both the US and the Netherlands, from 1996 to 2004 as an in-house international tax and transfer pricing counsel at Nestlé's HQ in Switzerland and from 2005 to 2015 as a Swiss based partner in globally operating transfer pricing boutique consultancy firms.
Hendrik has been providing transfer pricing advice to Swiss and foreign multinational clients in a variety of industries, covering design of transfer pricing systems, preparation of masterfile/local file documentation, negotiation and conclusion of unilateral/bilateral APAs, successful management of complex transfer pricing audits and setting up transfer pricing risk management frameworks.
Caterina Colling Russo has more than 15 years’ full-time experience in transfer pricing consulting. Before joining Tax Partner AG in 2016, Caterina has previously held specialist transfer pricing positions within global international tax and transfer pricing firms. She has worked in Amsterdam, London and Rome. She is a transfer pricing advisor for listed and non-listed Swiss and international Multinationals. Caterina is a speaker at tax seminars, and has published various articles and books on transfer pricing.
Monika Bieri has over 15 years of experience in national and international tax matters. She began her career as a tax consultant with Ernst & Young. After specializing in tax matters (LL.M. in International Taxation), she worked as a consultant in the tax department of an international insurance group. In 2016, Monika joined Tax Partner as a consultant on national and international corporate tax law issues. Her focus is on finance companies and real estate tax law. She also advises clients on transfer pricing and tax issues in the area of entrepreneurs – companies. She is the author of various publications in the field of national and international tax law.
