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KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Switzerland

KPMG survey regarding how local tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks

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December 10, 2025

Swiss tax law does not include specific legislation or regulations on transfer pricing. However, the arm’s length principle is applied on the basis of various provisions. While there is no specific reference in Swiss law or regulations to the OECD revised guidance on the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks, this guidance is also followed by Swiss tax authorities because of their adherence to the OECD guidelines.

KPMG LLP tax professionals have surveyed KPMG member firms from around the world regarding how local tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks.

Read a December 2025 article*, part of a series, summarizing the survey’s findings with respect to Switzerland.

*This article originally appeared in Tax Notes International (December 1, 2025) and is provided with permission.

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