Federal Administrative Court judges on deductibility of management fees in real estate investment fund structure

The Federal Administrative Court of Switzerland ruled that management fees of roughly 20% of rental income paid by the Swiss real estate company of an international real estate investment fund to a related foreign investment adviser did not comply with the arm’s-length principle.

In an article published in the 22nd edition of ITR’s Special Focus Transfer Pricing Monika Bieri and Caterina Colling-Russo discuss this case to be judged soon by the Swiss Federal Supreme Court.