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Switzerland: EU Pharma Package Tax Implications

  • The proposed EU Pharma Package would require EU wholesale distributors to buy medicinal products only from sellers holding an EU wholesale distribution authorization (WDA) or manufacturing/import authorization (MIA).
  • This could pressure Swiss and other non-EU principal structures where goods move physically within the EU but invoicing and contractual flows run through a non-EU entity.
  • Any restructuring options—such as creating an EU principal, EU trading branch, or EU master distributor, or adapting existing flows—may trigger transfer pricing, profit allocation, exit tax, corporate income tax, VAT, and customs consequences.
  • Groups should review and plan now, as the rules are expected to apply from Q4 2028 and implementation may take significant time.

Source: bakermckenzie.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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