Der Grundsatz "dealing at arm's length" im interkantonalen Steuerrecht der Schweiz

Transfer pricing between affiliated companies has long been a focus of tax authorities. The profit allocation resulting from the application of transfer prices between affiliated companies also affects inter-cantonal relationships in Switzerland. In this Zurich dissertation, the author thoroughly analyzes the arm's length principle as it applies to transfer pricing between affiliated companies in the inter-cantonal context. The applicable tax law foundations, correction mechanisms, and legal remedies are comprehensively described and evaluated.