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To: Louis V. Lambrecht who wrote (56962)	12/5/2004 8:52:22 PM
From: Elroy Jetson	Respond to of 74559

So long as your pricing transfer scheme consists only of paper transfers from company to company, you will pay only the 15% Swiss profits tax and not incur any Swiss transit taxes. Of course, the non-market transfer-pricing designed to reduce taxes is, in most cases, a tax-fraud under EU nation rules. But evasion of EU nation taxes is not a crime in Switzerland. Though your operations in Greece and the UK would be criminal enterprises. Many years ago American companies had engaged in similar transfer pricing frauds until the IRS clarified the rules and stepped up enforcement. The Sabena transfer to Swissair simply gave Belgian politicians cover for washing their hands of a steady drain on the public purse. A not unexpected "path of least resistance" in Belgium, a nation of pissy busy-bodies who are the butt of jokes through-out Europe. Europe can "liberalize" their markets and transit systems all they like along modern American principles, but you won't see the Swiss joining the parade. Like your Mother told you, "If everyone was jumping off the cliff would you have to also?" .