Intra group services (treasury, administration, accounting etc) were performed and charged to a Swiss resident A AG. The payment for these services had been determined by application of the CUP method. The tax authorities found that the payment for the services had been to high and instead applied a cost-plus method which resulted in lower service fees. Judgement of the Supreme Court The court decided in favor of the tax authorities. A cost-plus method was more appropriate as The taxpayer had been unable to provide evidence of any third party pricing of comparable services The services provided were of a low-value-adding nature, for which the cost-plus method is more appropriate. Click here for English translation Click here for other translation ...