Transfer Pricing Recruitment: Spotlight series: Zurich
05 December 2016

Moving to Zurich brings you to one of the northernmost regions in eastern Switzerland, not far from the German border. Zurich is situated in a very scenic area with plenty of rivers and lakes and in convenient proximity to the Swiss Alps. Even if you are no winter sports fanatic, there are lots of reasons why expats keep moving to Zurich in droves. The canton is Switzerland’s economically strongest region, with expats drawn to the banking and insurance sectors in addition to the international consulting and legal powerhouses that continue to experience exponential growth.  A move to Zurich ensures participation in one of the most competitive economies worldwide and in one of Switzerland’s strongest regional economies. Recovering well after the financial crisis of 2008/2009, Switzerland remains robust during the Eurozone crisis. Relocation to Zurich allows you to enjoy an extremely high quality of life, ranking the city second out of more than 220 expat destinations worldwide. Whilst this may appear to come at a price, salaries, bonuses and additional benefits more than compensate - ensuring a very high standard of living for transfer pricing professionals across all levels of seniority. Organising your schedule for living in Zurich is made easier by the exceptional transport infrastructure. With easy train connections to a host of cities including Austria, France, Germany, Italy and the Netherlands, transfer pricing professionals are very much in the heart of an extremely dynamic region.

Country by country reporting – what’s in store for Swiss multinationals?

Draft legislation would require Swiss-parented multinational entities (MNEs) with annual consolidated group revenues of CHF 900 million or more to comply with new transfer pricing and transparency requirements, with the first country-by-country (CbC) report due for fiscal years beginning on or after January 1, 2018. However, Swiss MNEs could voluntarily file the CbC report for fiscal years beginning on or after January 1, 2016, in order to avoid certain exposures (e.g., penalties) in countries where CbC reporting requirements already have been introduced. In certain circumstances, Swiss group entities (other than Swiss-parented MNEs) would also be obliged to file CbC reports. Under the draft law, failure to provide the CbC report or providing an incorrect or incomplete CbC report would trigger a penalty of up to CHF 250,000. In addition, penalties of up to CHF 50,000 could be imposed for non-cooperation with the SFTA during the CbC reporting examination process.  Currently, it is not anticipated that Switzerland will implement other recommendations included in the BEPS Action 13 Report, such as the preparation of the transfer pricing Master file and Local file. However, Swiss MNEs are well advised to protect their intercompany arrangements by establishing and maintaining appropriate transfer pricing documentation. Finally, on April 12, 2016 the EU Commission (EC) proposed legislation requiring public disclosure of CbC reports for certain taxpayers.

Although Switzerland is not a member of the EU, the EC proposal introduces a reporting obligation for certain MNEs regardless of whether their headquarters are inside or outside the EU. Where an MNE group has its headquarters outside the EU, its medium and large-sized subsidiaries and branches in the EU would be required to file a CbC report for the whole group unless the non-EU parent makes the relevant information publicly available.

Visas and the importance of languages

Zurich has a fantastic international community with approximately 25% of the population being born outside of Switzerland. Considering the area’s excellent economic performance and its close proximity to Germany, it’s hardly surprising that a significant number of Germans or German speakers decide upon moving to Zurich. There are also sizable communities of tax and transfer pricing professionals from Italy, Portugal, Spain, Austria, France and the UK. Although the federal institutions of Switzerland have four official languages, this is not necessarily the case on a regional level, with German or Swiss German being the primary languages. The key thing to note is that whilst English is widely spoken in Swiss business culture, fluent German language skills are extremely important from a client relationship perspective. There are definitely some exceptions (particularly if you have financial services, economics or Value Chain/Business Restructuring expertise) however 90% of the opportunities that we recruit in Zurich require a strong command of both German and English as a prerequisite. With stricter immigration criteria than in previous years, transfer pricing professionals will need to be able to work freely in the EU without sponsorship to be considered for current opportunities in either Zurich or Geneva.

What could be expected from an ambitious transfer pricing professional who is focused on accelerating their career in Zurich? If you are considering such a move, Switzerland is considered a key European centre of excellence for Value Chain/BMO/OME projects (in addition to London and Amsterdam), therefore technical complexity is second to none. The majority of your project focus will be on the more challenging aspects of advisory work including planning, business restructuring, IP migration, dispute resolution, Swiss Patent Box/R&D, complex financial transactions, valuations, intra-group funding and cash-pooling. For a more comprehensive discussion about what a transfer pricing career in Switzerland can offer, please contact TP International’s Managing Director, Liz Tookey at lt@tpi-search.com